Further Comments : Media Access Canada / Access 2020

Document Name: 2015-134.223960.2530445.Further Comments (1$8$501!).doc
Media Access Canada (MAC) – Access 2020 Coalition of Disabilities Stakeholders
February 1, 2016
Ms. **** May-Cuconato
Secretary-General
CRTC
*** ***
Submitted Electronically
Re: Review of basic telecommunications services. Telecom Notice of Consultation
CRTC 2015-134 - MAC/Access 2020 Coalition reply comments/2nd intervention
**** Ms. May-Cuconato,
Media Access Canada (MAC) on behalf of the Access 2020 Group of Accessibility Stakeholders is pleased to submit the attached intervention in response to the proceeding noted above.

MAC requests to be made a party to this proceeding and the opportunity to appear before the Commission in Gatineau to further address issues under consideration by the Commission in the Notice of Proceeding. We request sign language interpretation and CART. We will contact you within the specified time frame if we require video conferencing. If you have any questions, please do not hesitate to contact the undersigned.

Sincerely yours,
**** Tibbs
Acting CEO
Basic Service:
Setting the Bar for Canadians with Disabilities
2nd Intervention/Comments of
Media Access Canada – Access 2020 Coalition of Disabilities Stakeholders
Regarding
Review of basic telecommunications services. Telecom Notice of Consultation CRTC 2015-134 (Ottawa, 9 ****)
Media Access Canada/Access 2020 Coalition
2nd Intervention/Reply Comments
Basic Service:
Setting the Bar for Canadians with Disabilities
Table of Contents
I. Executive Summary
II. Reply Comments
Appendix: MAC/Access 2020 Coalition stakeholder perspectives on basic communications services
Executive Summary
1. Media Access Canada (MAC)/Access 2020 Coalition of stakeholders represent a variety of national disabilities organizations with the objective of achieving full accessibility of broadcasting and communications services by 2020.

2. Accessibility and affordability of high quality and reliable Internet access services represents a key concern for our stakeholders. Our first intervention in this proceeding outlined our community’s perspective and proposed a number of specific solutions for improving the reliability and affordability of high-speed Internet access services Canadians with disabilities require in order to take advantage of the social and economic opportunities information and communication technologies can provide for our stakeholders.

3. In our first intervention MAC/Access 2020 submitted that the Commission should redefine high-speed Internet access via both fixed and mobile networks as a basic communications service. To implement this mandate, we recommended a number of specific measures the Commission could adopt to improve the reliability and affordability of basic Internet access services that are available to Canadians in general, and to persons with disabilities in particular. We also called for establishing a Disabilities Rights Office (DRO) at the CRTC, an important issue to our stakeholders dissatisfied with their ability to communicate with service providers, access basic services they require, and resolve disputes.

4. Since submitting our first intervention to this proceeding, we have had the opportunity to review the positions of other parties that have intervened in this proceeding. We are pleased that the vast majorities of the parties have a broadly similar perspective as MAC/Access 2020 Coalition stakeholders about the need for the Commission to redefine broadband Internet access as a basic service subject to universal service obligations and minimum service standards. We urge the Commission to consider this broad public interest perspective documented on the record of this proceeding and recognize high-speed Internet access as the basic and essential service that should be available to all Canadians, including persons with disabilities.

5. None of the parties in the proceeding has objected to our specific proposals for setting up a DRO at the CRTC, developing a National Disabilities Subsidy Fund (NDSF), or for the Commission to mandate that all operators provide at least one basic service high-speed Internet package that includes some minimum level of service quality guarantees in terms of sustained speeds (versus the current “best effort”, up to xMbps retail contracts for residential users).

6. The record of this proceeding clearly documents that reliability and affordability of access to high-speed Internet services represents a concern for various communities across the country, including rural and remote communities, as well as among Canadians with relatively low incomes. The vast majority of the parties support the Commission in recognizing that high-speed access is already an essential service. However, a small number of service providers have argued that no such a regulatory reform is required as market forces are adequate for achieving basic service objectives of the Telecommunications Act.

7. MAC/Access 2020 stakeholders tend to have relatively lower incomes than average Canadians, while persons with disabilities tend to have relatively high demand for reliable and symmetric high-speed data links required deploying educational, entertainment, business, assistive, and otherwise enabling technologies. Even though market forces on average might be perceived to be adequate for meeting the basic service needs of average Canadians by certain parties, averages are not necessarily relevant in the context of basic service needs of Canadians with disabilities and other vulnerable populations that continue to struggle with accessing basic high-speed Internet access at home or with mobile devices. Particularly for persons with severe or very severe disabilities with limited incomes, affordable access to basic Internet access services that meet their basic communications needs remains challenging.

8. MAC/Access 2020 Coalition recognizes the importance of market competition and innovation in addressing our basic communications needs. Recommendations outlined in our first intervention are designed to promote incentives of operators and the capacity of CRTC, to care more about the needs of Canadians with invest in the quality of services they deliver to all Canadians, including those with disabilities. Members of vulnerable populations such as MAC/Access 2020 stakeholders are likely to benefit more than average consumers if the Commission decides to adopt a policy framework that creates incentives for market participants to deliver a minimum service quality level at an affordable price. Even with such policies, persons with severe or very severe disabilities also tend to have very low or no incomes. Extending affordable access to reliable and affordable broadband connectivity to this group of our stakeholders is likely to require the adoption of a targeted subsidy mechanisms such as the NDSF model we proposed in our original submission.

9. In this second of our submissions, MAC/Access 2020 evaluates the positions of other parties in the context of our original recommendations and provides a disabilities perspective on the debate. Although MAC/Access 2020 see a great deal of support for our recommendations on the record, we fear that interests of Canadians with disabilities in this matter might get lost in broader debates about rural connectivity and minimum service quality standards. We support efforts by rural communities and broader consumer advocacy groups to convince the Commission to adopt a sustainable funding mechanism for addressing infrastructure and affordability concerns across Canada. In order to ensure the interests of the most vulnerable of Canadians with disabilities remain central to the deliberations, we use this opportunity to further elaborate on the NDSF needed for making basic communications services affordable to persons with severe and very severe disabilities who have little or no income.

Media Access Canada/Access 2020 Coalition

10. MAC mandate: Media Access Canada (MAC)/Access 2020 Coalition is mandated to provide a united voice for a wide range of national organizations representing Canadians with disabilities in promoting public policies and business practices that improve accessibility, affordability, and quality of communications services available to our stakeholders.

11. Our proposals: Given the importance of questions raised in the CRTC 2015-134 Notice for Canadians with disabilities, MAC/Access 2020 submitted a number of specific proposals to the Commission in our original intervention that would help improve the quality and affordability of service available to Canadians with disabilities. We also proposed establishing a Disabilities Rights Office (DRO) at the CRTC for improving communications and help resolve disputes between Canadians with disabilities trying to access basic services and service providers.

12. Evidence and positions of the parties as they relate to MAC/Access 202 proposals: We have had the opportunity to review submissions and interrogatories from the wide-range of parties to the proceeding.

13. Emerging consensus: Overall, MAC/Access 2020 Coalition is pleased to see that most of the parties to the proceedings recognize that fixed and mobile broadband Internet access have become essential to the ability of Canadians to engage in social and economic activities. We were also pleased that the vast majority of parties agree that the Commission should recognize this fact in law and therefore redefine broadband access as an essential basic service and adopt policies that ensure all Canadian can have access to reliable and affordable Internet access services via both fixed and mobile devices. As detailed in our original submission, concerns about service quality and affordability are particularly acute in the disabilities community and we support both private and public sector initiatives that are effective in addressing these concerns by our stakeholders.

14. Divergent perspectives and solutions: Although there is substantive agreement among the parties that broadband access has already become the most basic of communications services and Canada’s regulatory framework should catch up with this technological and economic fact, proposed approaches to ensuring that all Canadians can access reliable and affordable services of sufficient quality vary significantly across service providers, consumer advocacy groups, and other parties. MAC/Access 2020 Coalition have serious concerns about some of the evidence and arguments provided by parties that contend there are no problems to be solved with the adoption of a legally binding basic service mandate, that so-called “market forces” are sufficient for addressing the basic needs of all Canadians, or conjecture that access, affordability, and quality of service issues represent a policy problem only in high-cost rural and remote communities. We address these issues in the context of three essential elements of the recommendations we outlined in our 1st submission to this proceeding with the objective of improving accessibility, affordability, and quality of basic communications services that are available to Canadians with disabilities.

15. Multiple digital divides: MAC recognizes that access and affordability are an important concern in high cost rural communities where market forces are weak, private sector providers have limited incentives to invest, and public subsidies or other policy inducements might be required to promote affordable access to high-speed Internet connectivity. We would like to add that relatively limited competition also makes basic services less affordable in rural communities, which is a problem for all Canadians that live and work outside of Canada’s urban centres, including vulnerable communities such as persons with disabilities, seniors, children in low-income households. Due to the clear potential for market failures in the provision of access in rural communities, MAC agrees with parties that have submitted the Commission should adopt some form of rural cross-subsidy mechanism by collecting an adequate fee from dominant fixed and mobile telecom network operators. However, we strongly disagree with large service providers who have argued the Commission should only be concerned with extending access to under-served rural communities. This argument is based on the implicit assumption that market forces are sufficient in urban Canada to provide reliable and affordable services of a high quality. This assumption is both logically and empirically flawed as it does not take into account diverse challenges and needs of under-served sub-groups of the population that reside in both urban and rural communities.

16. The Need for a multipronged basic service strategy: Reliability and affordability concerns of vulnerable populations such as Canadians with disabilities are not limited to those who live and work in underserved rural communities. Consequently, we support efforts to develop a multipronged cross-subsidy mechanism that includes both an infrastructure subsidy fund to promote private sector incentives to invest in high cost areas and a funding mechanism to improve affordability of reliable services to vulnerable populations (e.g. the general approach proposed by the Affordable Access Coalition (AAC)). Given that average prices for Internet access subscriptions in Canada tend to be some of the highest in the OECD countries and low cost options are relatively limited for those with low disposable income in the Canadian market,[footnoteRef:1] persons with low or no income will continue to face significant challenges in accessing reliable and affordable basic services of a high quality. [1: http://www.oecd.org/sti/broadband/oecdbroadbandportal.htm Table 4.1.] 17. Disabilities perspective on affordability of basic services: In our first intervention, MAC/Access 2020 Coalition submitted that the Commission should adopt a National Disabilities Subsidy Fund (NDSF) in order to ensure that Canadians with disabilities have access to reliable and affordable communications services of a high quality as mandated under Section 7 of the Telecommunications Act. In the context of various proposals submitted by other parties regarding industry funded cross-subsidy mechanisms targeting rural market failures and affordability concerns by Canadians in general terms, MAC/Access 2020 Coalition fear that concerns by our stakeholders might get lost in broader debates in this process among dominant network providers and advocacy groups with a broad public interest agenda to improve quality and affordable access for all Canadians. If the Commission chooses to redefine high-speed Internet access (fixed, mobile, or both as MAC and various other parties to the proceeding have proposed) as a basic service under the Telecommunications Act, then we submit that a fixed and predictable portion of the funds that are to be collected should be allocated to the NDSF in order to improve affordability of access to Canadians with disabilities that have very low or no disposable income. In order to ensure that Canadians with disabilities are not left behind, we submit the Commission should allocate a specified proportion of total funds to be collected from dominant operators to the NDSF that MAC/Access 2020 Coalition proposed in our first submission to this proceeding. The segregated funding mechanism needed to improve access for Canadians with disabilities should target improving the quality and affordability of fixed and mobile services that are available to Canadians with severe or very severe disabilities.

18. Prevalence of disabilities: If the Commission choses to redefine high-speed access as a basic service that should be available at affordable prices to all Canadians, a needs based approach to allocating scarce public funds will be critical to their effectiveness in targeting vulnerable individuals and groups. Statistics Canada’s Canadian Survey on Disability (CSD) from 2012 provides the most recent attempt to measure the prevalence of disabilities in Canada. According to Statistics Canada’s estimates based on the 2012 CSD 3.8 mil. Canadians suffered from at least one type of disability that limited their daily activities, or approximately 14% of the population.[footnoteRef:2] As documented in Table 1, the prevalence of disabilities grows with age, starting at around 40 years old, and tends to be higher in women.[footnoteRef:3] Around half of this total, or approximately 7% of the Canadian population, are estimated to have severe or very severe disabilities, while around 30% of the total identified having a mild disability. More than 80% of persons with disabilities use aids or assistive devices. [2: http://www5.statcan.gc.ca/olc-cel/olc.action?objId=89-654-X&objType=2&lang=en&limit=0 ] [3: http://www.statcan.gc.ca/pub/89-654-x/89-654-x2015001-eng.htm] Table 1: Prevalence of Disabilities in Canada

Age groups
**** sexes
Men
Women
% of Total
15 and over
13.7
12.5
14.9
15 to 64
10.1
9.5
10.7
15 to 24
4.4
4.5
4.3
25 to 44
6.5
6.0
7.1
45 to 64
16.1
15.2
17.1
65 and over
33.2
30.8
35.2
65 to 74
26.3
25.0
27.5
75 and over
42.5
39.8
44.5

19. Nature of disabilities: Table 2 provides an overview of prevalent types of disabilities. The most common forms of reported disabilities are those relating to pain, mobility, or flexibility, with over 11% of Canadians experiencing one of the three, 40% of which report having all three.

Table 2. Types of Disabilities
Disability type
% of total
Pain
9.7
Flexibility
7.6
Mobility
7.2
Mental/psychological
3.9
Dexterity
3.5
Hearing
3.2
Seeing
2.7
Memory
2.3
Learning
2.3
Developmental
0.6
Unknown
0.3

20. Employment and income: Just under half of Canadians with disabilities between 15 and 64 were employed, which is substantially below the rate for Canadians without disabilities (47% versus 74%). Unemployment increases substantially with the severity of the disability. For example, only around 26% of very severely disabled were employed as compared to 65% of those with mild disabilities. According to Statistics Canada estimates, the self-reported total median income of persons with disabilities is only around 2/3 of persons without disabilities ($20,000 versus $31,000). This gap increases sharply with the severity of the disability, with those that have severe and very severe disabilities reporting a median income that is less than half of Canadians without disabilities ($15,000 versus $31,000). This pattern is particularly acute for persons with disabilities of a working age (15-64). It is precisely because of this that MAC/Access 2020 Coalition propose that a commensurate portion of any aggregate funding mechanism that Commission adopts in this proceeding should be targeted to Canadians with severe and very severe disabilities with low or no income.

21. NDSF targeting and means testing: As noted, Canada has some of the highest prices in the world in terms of both fixed and mobile access. This makes it particularly challenging for persons with disabilities and low incomes to access the wide range of existing and emerging Internet applications that provide them with assistive, educational, social, and economic opportunities. To provide a first estimate of the cost of the proposed NDSF, consider the fact that around 14% of Canadians have some form of disability. Providing full or partial subsidies to this substantive proportion of the population would be obviously very expensive and potentially inefficient as the economic impact of disability on income is lower for persons with less severe disabilities and those with other means of financial support. Focusing on those with severe and very severe disabilities, which make up around 7% of the population, would still require substantive funding commitments. Using means testing based some measure of income would help target any potential funds to those who are most vulnerable. If individuals with severe and very severe disabilities are considered eligible for future affordability subsidies that have incomes below the median of $15,000 per year noted above for this sub-group, approximately 1 out of 4 Canadians with disabilities could potentially be eligible (around 3% of the population, or 1 million Canadians). Some proportion of this group will not necessarily take up the subsidies (e.g. vouchers distributed through social service organizations already working with the severe and very severely disabled), which means the actual number of target population the mechanism needs to cross-subsidize will likely be less than this benchmark.

22. Costing NDSF: Depending on the set of services CRTC ultimately includes in the basic service framework, the cost of covering even this very small and narrowly defined group of Canadians with disabilities will easily run into the hundreds of millions of dollars per year. Consequently, ensuring that basic communications services are affordable for our stakeholders will require a substantive increase in commitments by policymakers to the needs of Canadians with disabilities. For example, according to CRTC CMR data, average revenues for a fixed Internet service package with an advertised speed between 1.5-4 Mbps is currently around $50 per month (excluding modem rentals and other fees).[footnoteRef:4] A full $50 subsidy targeting very low income and severely disabled Canadians and reaching ½ of the 1 mil. persons who may be eligible under the means testing approach to NDSF noted above would require approximately $300 mil. per year, while a partial subsidy that covers only one half of the cost of basic service for this amount would be around $150 mil. per year. MAC/Access 2020 therefore submit that between $150 and $300 mil. would be needed to fund the narrowly focused need based NDSF mechanism required to extended affordable access to the Internet some of the most vulnerable Canadians with disabilities. Although we suspect that some parties to this proceeding who contend that market forces will address policy concerns about affordability of access may find this to be too expensive, MAC/Access 2020 stakeholders submit that the economic benefits extending affordable access to the most vulnerable members of our community will significantly outweigh its accounting costs. [4: CRTC CMR 2015. Table 5.3.6.] 23. Remaining gaps and tax credits: If the Commission chooses to define broadband access as a basic service, MAC/Access 2020 note that the targeted nature of NDSF will still leave significant gaps in affordable access to basic service for our stakeholders that would not necessarily be eligible for the funds from NDSF. Since only one quarter of the nearly 4 mil. Canadians with disabilities would qualify under the model sketched above, tax credits might be a viable option for enhancing the affordability of basic services for Canadians with disabilities with higher incomes. Even though tax policy is beyond the purview of the CRTC, we encourage the Commission to convey our message about this issue to Industry Canada and other federal policymakers. Access to reliable and affordable Internet connectivity can generate significant cost savings and quality improvements in the delivery of social services and healthcare to Canadians with disabilities. In this context, direct outlay through the NDSF and tax credits for accessing basic communications services could potentially lead to long term budgetary savings for federal, provincial, and municipal governments.

24. Market forces and access: Although ensuring all Canadians, including those with disabilities, have access to basic communications services will require a combination of subsidies and tax credits, we recognize the importance of policies that promote the incentives of private service providers to compete with each other to enhance affordability and quality of service they deliver. Unfortunately, in network industries such as telecom and broadcasting where a small number large providers dominate the provision of retail access, competitive discipline on pricing is often limited and affordability of access to vulnerable populations becomes a public policy concern. Consequently, MAC/Access 2020 Coalition support the Commission in its recent efforts to increase competition and investment in advanced fibre-to-the-premises (FTTP) technologies in the market for wholesale Internet access services. More wholesale market competition can provide some measure of pricing discipline and allow for service differentiation by multiple providers specialized in serving particular communities of end users with distinct needs, including Canadians with disabilities. Similarly, we strongly disagree with parties to this proceeding that argue there are no problems in the regulation of the retail market for fixed and mobile services that the Commission needs to or should solve by adopting policies that improve transparency of retail market transactions, accountability of dominant operators, and commitments of suppliers to deliver minimum actual service quality levels the Commission defines as basic in its determinations pursuant to this proceeding.

25. Market and regulatory transparency: The record of this proceeding is replete with debates between and evidence provided by large service providers and public interest consumer advocacy groups about gaps between advertised and actual speeds of connectivity in the Canadian market. Operators emphasize speeds they advertise and go on to say they are sufficient, while consumer groups demonstrate that actual speeds operators deliver can fall significantly below actual rates. Given the importance of service quality and reliability for deploying applications our stakeholders require, we submit that the Commission should use actual broadband network measurements, rather than indicators of advertised “best effort” speed, to evaluate the extent to which existing 5 Mbps down and 1 Mbps upload minimum speed targets are delivered during high traffic periods.

26. Beyond “best effort”: As detailed in our 1st intervention, access to reliable and affordable Internet connectivity represents a critical element of the ability of Canadians with disabilities to take part in social and economic activities. Over the past decade, a wide range of Internet applications have evolved that help enhance the quality of life and opportunities for persons with various types of disability. The ability of Canadians with disabilities to deploy these enabling applications depends on the availability of fixed and mobile broadband networks that are able to deliver high-speed and symmetric connections with minimum service quality guarantees. However, service providers in Canada only offer retail Internet access services in the residential market on a best effort basis (i.e. “up to xMbps). In our first submission, we conjectured that large service providers all have the technical capacity to use advanced network control technologies they utilize to differentiate service quality across end users and applications to deliver a basic service package that includes minimum service quality guarantees and meets the technical requirements of our stakeholders. This conjecture has now been confirmed on the record of this proceeding in responses by large operators to interrogatories by OpenMedia regarding the feasibility of mandating a minimum level of service quality guarantees for users that require more reliable basic services. Most of the large incumbents acknowledge that they have the technical capability of delivering such guarantees, and in fact many do so on demand for large customers for a price. However, the operators argue that they do not offer such guarantees to individuals and small businesses because of a purported lack of demand. Importantly, operators do not provide any evidence on the record that supports their contention about a lack of demand for service packages that deliver guaranteed minimum speeds across different application providers and over time. MAC/Access 2020 Coalition understands that the average user may not demand minimum service quality guarantees and might be satisfied with “best effort” service packages and uncertain levels of service. However, a wide range of advanced educational, assistive, and otherwise enabling applications that would improve the lives of our stakeholders require such guarantees for their reliable and safe utilization.

27. A standards-based approach to basic service: Given the technical feasibility of delivering minimum service guarantees and the significant reliability improvements they would involve relative to the current “best effort” offerings, in our original intervention MAC/Access 2020 Coalition recommended the Commission should mandate operators to offer at least one basic subscription package that offers service quality guarantees to end users whose particular needs require it. As we detailed in our first submission, this standard-based solution would minimize the potential for interference with market forces as the operators would be free to offer whatever “best effort” packages they want in addition to the basic service package the Commission mandates they should make available to any end user that requires minimum service guarantees. The fact that operators that dominate the Canadian retail market have acknowledged that they have already installed the necessary network control technologies, and in fact do deliver minimum guarantees of service quality on demand to business users, suggests that they can also do so for the rest of residential and business users requiring such basic guarantees from their access providers. We therefore reiterate our request in this proceeding to define a “basic service” package that includes such guarantees across content providers, applications, and at any time (e.g. 5/1 Mbps, 5/5 Mbps, or 10/10 Mbps if possible on fixed access; minimum service standards for mobile access could be lower due to technological differences). Our proposed approach would also help address concerns about traffic management/throttling policies that can slow access to Internet applications and content services our stakeholders require.

28. Retail market transparency, quality, and affordability: In contrast to the operators who argue market forces will solve all concerns (except perhaps in high-cost remote communities), the standards-based approach proposed above has the potential to enhance market forces in the provision of reliable and affordable basic services needed by all Canadians by making suppliers more accountable for the services they deliver. Reducing uncertainties about service quality would be to the advantage of operators that invest more in achieving service levels they have promised their customers in retail contracts by enabling end users who require service quality guarantees to opt out of the “best effort” market. Since large operators already have installed network control technologies that enable them to offer such guarantees, adopting our proposal is likely to require little additional investment for them.[footnoteRef:5] While the evidence on the record of this proceeding clearly illustrates that it is feasible to implement our recommendation about mandating at least one package with service quality guarantees with minimal cost, questions about the price at which operators would have to sell this basic service package, minimum standards of service to be incorporated, and how can customers verify actual service quality will have to be considered; that is if, as we hope, the Commission chooses to redefine high-speed access as a basic service and adopt the approach we have proposed. [5: Please note this may not be the case for smaller operators who have not yet invested in advanced network control and traffic flow differentiation technologies.] 29. Verification of minimum basic service standards: The 5/1 Mbps minimum service objectives the Commission adopted in 2011 have been interpreted as “aspirational” targets large broadband operators than 90% of Canadians. These parties continue to maintain that the Commission should continue with the same approach by keeping “aspirational” standards, rather than adopting hard and verifiable minimum service quality standards. The fact that operators are very reluctant to estimate and disclose what proportion of connections that they deliver to end users fall below or above the 5/1 Mbps minimum service levels the CRTC adopted years ago underscores the importance of verification and hard targets in redefining high-speed Internet access as a basic service under the Telecommunications Act. If the Commission chooses to redefine broadband as a basic service essential to the needs of all Canadians, then MAC/Access 2020 Coalition submits it should also adopt a standardized mechanism that enables each end user to verify if they are getting the speeds either as advertised (in case they are on a “best effort” plan) or minimum guaranteed (in case they are on a basic plan with minimum service guarantees) speeds they have been promised by their service provider. The SamKnows approach to speed testing adopted by the Commission in agreement with dominant service providers is a closed testbed limited to selected participants, and therefore does not allow our stakeholders or other Canadians that are not part of the SamKnows testbed to verify what they are getting from their network operators. Instead, we recommend the Commission adopt the testbed that has recently been deployed by the Canadian Internet Registration Authority (CIRA) as a tool for enabling any end user to verify the quality of service using a standards-based methodology provided by a relatively independent third party.[footnoteRef:6] In addition to being open to any customer to use, the CIRA Internet Performance **** (IPT) provides various metrics to end users and regulatory authorities that help identify if causes for unreliable and low quality services can be attributed to end user equipment shortcomings or congestion/under-provisioning by their network provider. The results of the CIRA IPT can provide valuable evidence to the CRTC, CCTA, or in the courts in case of misleading advertising claims, if and when particular operators oversell their capacity (i.e. under-invest) and therefore fail to meet the service quality levels they have promised to customers or minimum standards for basic service as mandated by the Commission at the conclusion of this proceeding. [6: https://cira.ca/performance ] 30. Disabilities Rights Office (DRO): Our proposal for a DRO in MAC/Access 2020’s first submission remains unique and none of the parties have provided any evidence or arguments opposing our proposal regarding the establishment of a DRO at the CRTC with the mandate to provide a disabilities perspective on access, service quality, and affordability and to enable our stakeholders to communicate with service providers in a constructive manner. Since our fist submission in this proceeding, we were pleased to have the opportunity to participate in the CRTC 2015-239 proceedings regarding the structure and mandate of the Commissioner for Complaints for Telecommunications Services Inc. (CCTS) and discuss various options with the Commission for setting up a DRO at the CRTC. We were particularly pleased that Commissioner **** found that we have presented “a fairly well-formed call for a DRO” as part of the CCTS review process.[footnoteRef:7] We urge the Commission to build on our proposal as soon as possible, either as part of its forthcoming decision regarding the CCTS review, as part of this proceeding on the availability of basic services to all Canadians, or to initiate a separate proceeding focusing on the structure and mandate of a DRO at the CRTC. MAC/Access 2020 Coalition reiterates our willingness to help the CRTC set up an effective DRO and engage with service providers to improve their capacity to accommodate basic customer service and dispute resolution needs of Canadians with disabilities. We submit that the question of a DRO is within the scope of both CRTC 2015-239 and CRTC 2015-134 proceedings. MAC/Access 2020 Coalition strongly believe in the importance of a DRO for improving accessibility of basic services to our stakeholders, reducing the costs to service providers of serving Canadians with disabilities, and encouraging operators to care more about the basic communications needs of Canadians with disabilities for access to services they consider essential. Although it is not really relevant which of the proceedings the Commission utilizes to respond to demands by our stakeholders for a DRO, we hope that it takes action on this important issue to Canadians with disabilities as soon as possible. [7: CRTC 2015-239 transcript, Vol. 2, paragraph 1656.] 31. From specialized services to basic broadband access: Over the past few years, the CRTC has increasingly recognized that market forces often fail to meet the needs of Canadians with disabilities and that innovative policy solutions are necessary. This basic service proceeding has generated further questions by the Commission and various parties about the relevance of defining specialized services such as Video Relay Service (VRS) as a basic service under the Telecommunications Act. Operators who oppose adoption of basic service obligations on high-speed fixed and mobile data access have also opposed making specialized services such as VRS a basic service. For example, in response to an RFI from the Commission, Shaw concedes that “specialized telecommunications services like Message Relay Service, IP Relay and Video Relay Service (VRS) enable Canadians with disabilities to access and participate in the digital economy”, but goes on to contend that “However, Shaw does not consider it necessary to incorporate VRS in the basic service objective.”[footnoteRef:8] On the other hand, the Canadian Hearing Society highlights that “VRS will provide functional equivalency to telephone services for Deaf and hard of hearing consumers” and therefore should be defined as a basic service.[footnoteRef:9] MAC/Access 2020 Coalition agree with the position of the Canadian Hearing Society regarding the status of the specialized and centrally administered VRS service that is currently under development. Furthermore, we think it is important to reiterate the point emphasized by the Deaf Wireless Canada Committee that the utilization of specialized services such as the VRS and other IP based applications can have a significant impact on the data usage of Canadians with disabilities on both fixed and mobile service plans.[footnoteRef:10] Lower than expected connectivity speeds, data caps, excessive use overcharges and throttling of service above a certain usage threshold limit reliability and affordability of specialized services designed for the disabilities community. These realities of the market can have a large negative impact on the ability of Canadians with disabilities to deploy specialized services such as VRS, as well as the wide variety of other network-intensive applications and services that have emerged on the global market to serve the needs of persons with disabilities. Competition and innovation in the global market for applications that serves our needs provides a range of new tools that help enable our members to engage in social and economic activities. It is precisely for this reason that MAC/Access 2020 submits the Commission should define both fixed and mobile high-speed Internet data access as a basic service and should adopt a standards-based approach to achieving its basic service objectives. [8: Responses to Request for Information by the CRTC from Shaw, 2 November 2015, page 1.] [9: Response to Request for Information by the CRTC from the Canadian Hearing Society, 27 November 2015.] [10: Responses to Request for Information by the CRTC from the Deaf Wireless Canada Committee, 21 November 2015.] 32. [bookmark: _GoBack][bookmark: KVWin_undoend]Accessible services and wireless handsets: The CRTC basic services regulatory framework must include access to wireless telecommunication services for all Canadians with disabilities. We believe this should include, for example: text messaging, e-mail, instant messaging, and video communications” as is similarly required under US regulation[footnoteRef:11]. To ensure all users can take advantage of these services, we submit the Commission should clarify Broadcasting and Telecom Regulatory Policy CRTC 2009-430 in relation to: “offer at least one mobile handset for persons who are blind and/or have moderate to severe mobility or cognitive disabilities” to clearly define ”moderate” and “severe” so that it is clear what type of functional limitations need to be addressed to meet those individuals who fall into these categories particularly those with severe mobility disabilities. In addition, we submit that telephone providers not only must offer a bona fide accessible mobile handset for these individuals but they must also provide support to these individuals so they can appropriately select and then set up the handset in such a way that it works effectively for them. [11: As similarly defined under the Twenty-First Century Communications and Video Accessibility Act of 2010 (https://www.fcc.gov/encyclopedia/twenty-first-century-communications-and-video-accessibility-act-0 ).] Appendix: MAC/Access 2020 Coalition stakeholder replies to

the basic services consultations

“My opinion, doubtless endorsed by most blind people, is that on top of the time consumed for a screen reader and a print enlarger to organize and deliver a screen full of information, the time necessary to deliver that screen can only make browsing more slow and tedious. While certain modes of video compression keep important elements of the screen which don't change, for redelivery, screen reading technology interrogates the entire screen for any change. Hence, there is no time. Decrease in the use of partial refills.” “It's obvious that the seeing user desires…. higher speeds, and there is no reason to believe that low vision or blind people have any less desire. In simple terms, the compounding complexity of screen readers with slow data speed, prolongs the waiting.”“A part of blindness seldom discussed, is boredom. **** people cannot easily look around the room at pictures on the wall, or out the window to see the birds in the trees, or doodle. So one may daydream, scheme, or count the ticks of the clock. Hence, quick data recovery can make one's Internet experience much more comfortable.”“Unemployed and retired blind people have found a whole new world of interest, adventure, and purpose in their computing devices, and like their seeing peers, many spend the whole day reading newspapers, in audio chat rooms, on list serves, on Facebook, on twitter, and listening to audio streams of recorded materials, frequently with description.”“Communities of blind people, like their seeing peers, on the Internet trade audio from their DVD collections, especially items with DVS tracks. These audio files can be 1 to 200 MB, even when compressed, and downloading can take time. Downloading tends to be preferred as streaming can be inconsistent at times of Internet congestion or server failure.”“Also, blind people packed material onto portable MP3 type players or their phones to listen while traveling, waiting in doctors offices, or relaxing on the deck. Remember now, writing in the car or on the bus can be incredibly boring because one cannot people watch or look out the window.”“Please do not accept these latter comments is gratuitous, as I thought it important for you to understand how easily captured audio can be a main prop in upholding one's peace of mind and life interest. While library books are all well and good, blind people like to stay in tune with all aspects of modern culture, and these days for blind people, much of that comes from the Internet. It goes without saying that this should be made possible without complications and consuming the least time possible.”“At home, or when visiting, and a movie is being shared, conversation goes on with the odd pause for an exciting moment. As you would appreciate, conversation drowns out the movie, both by volume, and often by interesting content. Clearly, without a visual path, one must totally concentrate on the audio: voices, sound effects, and possible description, to follow. Movies often have complicated plots with nearly simultaneous scenes and or time shifts, and everyone knows what that's like. Without a rewind function. So my mode, is to find the audio description recording out there, and play it back to myself with total control of volume, fast forward, and rewind. For me, at least, conversation in a movie doesn't work.”“The podcast world has become so rich that it takes more of my entertainment time every day. While YouTube is very interesting, I get a great deal of material that has been described from my British colleagues who extract it and post it online to an exclusive user group. Believe me, send space is our friend.” “Noting above the predilection of some blind people to consume audio only, for blind people living alone, one could argue that they are paying for a major component of the service that they cannot use. Hence, a specialty economy connection option makes good sense.”“Don’t know how much national attention this attempt to cap Internet broadband in rural areas is getting, but I figured you should know about what we are being told. This fee increase by Eastlink is going to create, and continue to enforce – a second class of telecommunication users.

(That is, those users in rural areas, whether they are disabled or abled.) It is very strange that people in urban centres - or rurally in other provinces - do not use Netflix and/or do the same streaming as those in rural Nova Scotia do.”

“And it also irks me considerably that …… a spokesman for Seaside Wireless Communications could come out and say that the Broadband for Rural Nova Scotia program was “a pretty visionary project.” That speed was merely what all telecommunications suppliers/sellers were supposed to be doing! And as a former journalist and now a communications consultant, he should know that. The upgrade that Seaside Wireless is embarking on – with federal help – is just bringing them up to speed ... to the minimum of what they should be providing.”Comments collected from a town hall meeting of MAC/Access 2020 Stakeholders to discuss their access to basic communications service. Participants included cognitive, hard of hearing, low vision, senior, and other members of our community.

· One **** station across Canada, on all cable programming
· TV guide not on cable TV not useful for people with disabilities - electronic television listing
· People with acquired brain injury struggle with estimating data, voice usage, etc., not only brain injury but everyone
· Free long distance education, who pays for it, get 1100 free online courses from online universities (iv league), download them even from YouTube, 30,000 hours of free lectures - free long distance education
· Free online webinars
· Funded infrastructure - should be available for everyone
· All basic telecom infrastructure should be reviewed
· Digital literacy, cap sites in Nova Scotia, to improve digital literacy for everyone in the community including the disabled

· The balance between freedom of action and freedom of speech and access to service, difficult balance, if we can't run this program (cap) and prevent the bad elements from outweighing the good, then we'll cancel it - still exists in nova scotia but not elsewhere· Almost every library has problems with this, not always in libraries either - open access computers, hard to supervise

· Lack of usage for cap in sask, we had it, it was free but nobody would use it, most people would go to the Y or the library and pay for computer lessons
· High cost service areas where 5 mbps down and 1 mbps up, you're only as good as your weakest link
· Remote areas, sask, bc, mb, nova scotia too, many places with no coverage because of geography, nova scotia should be included in the list of remote places where coverage is poor

· Telehealth is not used to broadcast meetings across the province because of confidentiality, but in hospitals they have monthly meetings in Halifax but only if you attend the meeting in person but they don't have them broadcast online, they say it's because of confidentiality· Recently a major accessibility issue because most of the provincial services are going to 1800 numbers but people with cell phones that do not have a plan can only text, we bought a cell phone at one clinic so that we could receive text, deaf text only as well, going to only 1800 numbers will lose all the people who text or are below the low income cut off and cannot afford a cell plan. conversely I wouldn't want everything to go to text since some people don't have cell phones, not a single point of entry or communication, we need multiple avenues, if I cannot call the welfare office I should be able to email, text or visit them in person· Transition article - digital immigrant - person applying for welfare was given a piece of paper with a website address to apply for welfare

· Not only people with disabilities, this benefits everybody

· 2009, CP Saskatoon, applied and rejected from Canadian paraplegic in sask discounted cell phone if you get a membership to CP assoc, neurologic condition, qualifications are CP, company gave sponsorship deal with CPA, not CP but neurological disability, if you aren't a paraplegic why would I think to become a member, it's not really any cheaper than getting a cell phone from most companies anyways· Even with all the monthly fees, the cell phone expense and programs and internet and computer are very expensive to purchase, getting all three packages a month is very costly, people who are low income cannot afford it

· If you are on social assistance, connectivity is never seen as a necessity of life, this is a mistake, people who are low income need this, kids learn from tv and internet now, this should be necessities
***End of Document***
20

Further Comments : Media Access Canada (Intervenor 693)

Document Name: 2015-134.223960.2530445.Further Comments (1$8$501!).doc
Media Access Canada (MAC) – Access 2020 Coalition of Disabilities Stakeholders
February 1, 2016
Ms. **** May-Cuconato
Secretary-General
CRTC
*** ***
Submitted Electronically
Re: Review of basic telecommunications services. Telecom Notice of Consultation
CRTC 2015-134 - MAC/Access 2020 Coalition reply comments/2nd intervention
**** Ms. May-Cuconato,
Media Access Canada (MAC) on behalf of the Access 2020 Group of Accessibility Stakeholders is pleased to submit the attached intervention in response to the proceeding noted above.

MAC requests to be made a party to this proceeding and the opportunity to appear before the Commission in Gatineau to further address issues under consideration by the Commission in the Notice of Proceeding. We request sign language interpretation and CART. We will contact you within the specified time frame if we require video conferencing. If you have any questions, please do not hesitate to contact the undersigned.

Sincerely yours,
**** Tibbs
Acting CEO
Basic Service:
Setting the Bar for Canadians with Disabilities
2nd Intervention/Comments of
Media Access Canada – Access 2020 Coalition of Disabilities Stakeholders
Regarding
Review of basic telecommunications services. Telecom Notice of Consultation CRTC 2015-134 (Ottawa, 9 ****)
Media Access Canada/Access 2020 Coalition
2nd Intervention/Reply Comments
Basic Service:
Setting the Bar for Canadians with Disabilities
Table of Contents
I. Executive Summary
II. Reply Comments
Appendix: MAC/Access 2020 Coalition stakeholder perspectives on basic communications services
Executive Summary
1. Media Access Canada (MAC)/Access 2020 Coalition of stakeholders represent a variety of national disabilities organizations with the objective of achieving full accessibility of broadcasting and communications services by 2020.

2. Accessibility and affordability of high quality and reliable Internet access services represents a key concern for our stakeholders. Our first intervention in this proceeding outlined our community’s perspective and proposed a number of specific solutions for improving the reliability and affordability of high-speed Internet access services Canadians with disabilities require in order to take advantage of the social and economic opportunities information and communication technologies can provide for our stakeholders.

3. In our first intervention MAC/Access 2020 submitted that the Commission should redefine high-speed Internet access via both fixed and mobile networks as a basic communications service. To implement this mandate, we recommended a number of specific measures the Commission could adopt to improve the reliability and affordability of basic Internet access services that are available to Canadians in general, and to persons with disabilities in particular. We also called for establishing a Disabilities Rights Office (DRO) at the CRTC, an important issue to our stakeholders dissatisfied with their ability to communicate with service providers, access basic services they require, and resolve disputes.

4. Since submitting our first intervention to this proceeding, we have had the opportunity to review the positions of other parties that have intervened in this proceeding. We are pleased that the vast majorities of the parties have a broadly similar perspective as MAC/Access 2020 Coalition stakeholders about the need for the Commission to redefine broadband Internet access as a basic service subject to universal service obligations and minimum service standards. We urge the Commission to consider this broad public interest perspective documented on the record of this proceeding and recognize high-speed Internet access as the basic and essential service that should be available to all Canadians, including persons with disabilities.

5. None of the parties in the proceeding has objected to our specific proposals for setting up a DRO at the CRTC, developing a National Disabilities Subsidy Fund (NDSF), or for the Commission to mandate that all operators provide at least one basic service high-speed Internet package that includes some minimum level of service quality guarantees in terms of sustained speeds (versus the current “best effort”, up to xMbps retail contracts for residential users).

6. The record of this proceeding clearly documents that reliability and affordability of access to high-speed Internet services represents a concern for various communities across the country, including rural and remote communities, as well as among Canadians with relatively low incomes. The vast majority of the parties support the Commission in recognizing that high-speed access is already an essential service. However, a small number of service providers have argued that no such a regulatory reform is required as market forces are adequate for achieving basic service objectives of the Telecommunications Act.

7. MAC/Access 2020 stakeholders tend to have relatively lower incomes than average Canadians, while persons with disabilities tend to have relatively high demand for reliable and symmetric high-speed data links required deploying educational, entertainment, business, assistive, and otherwise enabling technologies. Even though market forces on average might be perceived to be adequate for meeting the basic service needs of average Canadians by certain parties, averages are not necessarily relevant in the context of basic service needs of Canadians with disabilities and other vulnerable populations that continue to struggle with accessing basic high-speed Internet access at home or with mobile devices. Particularly for persons with severe or very severe disabilities with limited incomes, affordable access to basic Internet access services that meet their basic communications needs remains challenging.

8. MAC/Access 2020 Coalition recognizes the importance of market competition and innovation in addressing our basic communications needs. Recommendations outlined in our first intervention are designed to promote incentives of operators and the capacity of CRTC, to care more about the needs of Canadians with invest in the quality of services they deliver to all Canadians, including those with disabilities. Members of vulnerable populations such as MAC/Access 2020 stakeholders are likely to benefit more than average consumers if the Commission decides to adopt a policy framework that creates incentives for market participants to deliver a minimum service quality level at an affordable price. Even with such policies, persons with severe or very severe disabilities also tend to have very low or no incomes. Extending affordable access to reliable and affordable broadband connectivity to this group of our stakeholders is likely to require the adoption of a targeted subsidy mechanisms such as the NDSF model we proposed in our original submission.

9. In this second of our submissions, MAC/Access 2020 evaluates the positions of other parties in the context of our original recommendations and provides a disabilities perspective on the debate. Although MAC/Access 2020 see a great deal of support for our recommendations on the record, we fear that interests of Canadians with disabilities in this matter might get lost in broader debates about rural connectivity and minimum service quality standards. We support efforts by rural communities and broader consumer advocacy groups to convince the Commission to adopt a sustainable funding mechanism for addressing infrastructure and affordability concerns across Canada. In order to ensure the interests of the most vulnerable of Canadians with disabilities remain central to the deliberations, we use this opportunity to further elaborate on the NDSF needed for making basic communications services affordable to persons with severe and very severe disabilities who have little or no income.

Media Access Canada/Access 2020 Coalition

10. MAC mandate: Media Access Canada (MAC)/Access 2020 Coalition is mandated to provide a united voice for a wide range of national organizations representing Canadians with disabilities in promoting public policies and business practices that improve accessibility, affordability, and quality of communications services available to our stakeholders.

11. Our proposals: Given the importance of questions raised in the CRTC 2015-134 Notice for Canadians with disabilities, MAC/Access 2020 submitted a number of specific proposals to the Commission in our original intervention that would help improve the quality and affordability of service available to Canadians with disabilities. We also proposed establishing a Disabilities Rights Office (DRO) at the CRTC for improving communications and help resolve disputes between Canadians with disabilities trying to access basic services and service providers.

12. Evidence and positions of the parties as they relate to MAC/Access 202 proposals: We have had the opportunity to review submissions and interrogatories from the wide-range of parties to the proceeding.

13. Emerging consensus: Overall, MAC/Access 2020 Coalition is pleased to see that most of the parties to the proceedings recognize that fixed and mobile broadband Internet access have become essential to the ability of Canadians to engage in social and economic activities. We were also pleased that the vast majority of parties agree that the Commission should recognize this fact in law and therefore redefine broadband access as an essential basic service and adopt policies that ensure all Canadian can have access to reliable and affordable Internet access services via both fixed and mobile devices. As detailed in our original submission, concerns about service quality and affordability are particularly acute in the disabilities community and we support both private and public sector initiatives that are effective in addressing these concerns by our stakeholders.

14. Divergent perspectives and solutions: Although there is substantive agreement among the parties that broadband access has already become the most basic of communications services and Canada’s regulatory framework should catch up with this technological and economic fact, proposed approaches to ensuring that all Canadians can access reliable and affordable services of sufficient quality vary significantly across service providers, consumer advocacy groups, and other parties. MAC/Access 2020 Coalition have serious concerns about some of the evidence and arguments provided by parties that contend there are no problems to be solved with the adoption of a legally binding basic service mandate, that so-called “market forces” are sufficient for addressing the basic needs of all Canadians, or conjecture that access, affordability, and quality of service issues represent a policy problem only in high-cost rural and remote communities. We address these issues in the context of three essential elements of the recommendations we outlined in our 1st submission to this proceeding with the objective of improving accessibility, affordability, and quality of basic communications services that are available to Canadians with disabilities.

15. Multiple digital divides: MAC recognizes that access and affordability are an important concern in high cost rural communities where market forces are weak, private sector providers have limited incentives to invest, and public subsidies or other policy inducements might be required to promote affordable access to high-speed Internet connectivity. We would like to add that relatively limited competition also makes basic services less affordable in rural communities, which is a problem for all Canadians that live and work outside of Canada’s urban centres, including vulnerable communities such as persons with disabilities, seniors, children in low-income households. Due to the clear potential for market failures in the provision of access in rural communities, MAC agrees with parties that have submitted the Commission should adopt some form of rural cross-subsidy mechanism by collecting an adequate fee from dominant fixed and mobile telecom network operators. However, we strongly disagree with large service providers who have argued the Commission should only be concerned with extending access to under-served rural communities. This argument is based on the implicit assumption that market forces are sufficient in urban Canada to provide reliable and affordable services of a high quality. This assumption is both logically and empirically flawed as it does not take into account diverse challenges and needs of under-served sub-groups of the population that reside in both urban and rural communities.

16. The Need for a multipronged basic service strategy: Reliability and affordability concerns of vulnerable populations such as Canadians with disabilities are not limited to those who live and work in underserved rural communities. Consequently, we support efforts to develop a multipronged cross-subsidy mechanism that includes both an infrastructure subsidy fund to promote private sector incentives to invest in high cost areas and a funding mechanism to improve affordability of reliable services to vulnerable populations (e.g. the general approach proposed by the Affordable Access Coalition (AAC)). Given that average prices for Internet access subscriptions in Canada tend to be some of the highest in the OECD countries and low cost options are relatively limited for those with low disposable income in the Canadian market,[footnoteRef:1] persons with low or no income will continue to face significant challenges in accessing reliable and affordable basic services of a high quality. [1: http://www.oecd.org/sti/broadband/oecdbroadbandportal.htm Table 4.1.] 17. Disabilities perspective on affordability of basic services: In our first intervention, MAC/Access 2020 Coalition submitted that the Commission should adopt a National Disabilities Subsidy Fund (NDSF) in order to ensure that Canadians with disabilities have access to reliable and affordable communications services of a high quality as mandated under Section 7 of the Telecommunications Act. In the context of various proposals submitted by other parties regarding industry funded cross-subsidy mechanisms targeting rural market failures and affordability concerns by Canadians in general terms, MAC/Access 2020 Coalition fear that concerns by our stakeholders might get lost in broader debates in this process among dominant network providers and advocacy groups with a broad public interest agenda to improve quality and affordable access for all Canadians. If the Commission chooses to redefine high-speed Internet access (fixed, mobile, or both as MAC and various other parties to the proceeding have proposed) as a basic service under the Telecommunications Act, then we submit that a fixed and predictable portion of the funds that are to be collected should be allocated to the NDSF in order to improve affordability of access to Canadians with disabilities that have very low or no disposable income. In order to ensure that Canadians with disabilities are not left behind, we submit the Commission should allocate a specified proportion of total funds to be collected from dominant operators to the NDSF that MAC/Access 2020 Coalition proposed in our first submission to this proceeding. The segregated funding mechanism needed to improve access for Canadians with disabilities should target improving the quality and affordability of fixed and mobile services that are available to Canadians with severe or very severe disabilities.

18. Prevalence of disabilities: If the Commission choses to redefine high-speed access as a basic service that should be available at affordable prices to all Canadians, a needs based approach to allocating scarce public funds will be critical to their effectiveness in targeting vulnerable individuals and groups. Statistics Canada’s Canadian Survey on Disability (CSD) from 2012 provides the most recent attempt to measure the prevalence of disabilities in Canada. According to Statistics Canada’s estimates based on the 2012 CSD 3.8 mil. Canadians suffered from at least one type of disability that limited their daily activities, or approximately 14% of the population.[footnoteRef:2] As documented in Table 1, the prevalence of disabilities grows with age, starting at around 40 years old, and tends to be higher in women.[footnoteRef:3] Around half of this total, or approximately 7% of the Canadian population, are estimated to have severe or very severe disabilities, while around 30% of the total identified having a mild disability. More than 80% of persons with disabilities use aids or assistive devices. [2: http://www5.statcan.gc.ca/olc-cel/olc.action?objId=89-654-X&objType=2&lang=en&limit=0 ] [3: http://www.statcan.gc.ca/pub/89-654-x/89-654-x2015001-eng.htm] Table 1: Prevalence of Disabilities in Canada

Age groups
**** sexes
Men
Women
% of Total
15 and over
13.7
12.5
14.9
15 to 64
10.1
9.5
10.7
15 to 24
4.4
4.5
4.3
25 to 44
6.5
6.0
7.1
45 to 64
16.1
15.2
17.1
65 and over
33.2
30.8
35.2
65 to 74
26.3
25.0
27.5
75 and over
42.5
39.8
44.5

19. Nature of disabilities: Table 2 provides an overview of prevalent types of disabilities. The most common forms of reported disabilities are those relating to pain, mobility, or flexibility, with over 11% of Canadians experiencing one of the three, 40% of which report having all three.

Table 2. Types of Disabilities
Disability type
% of total
Pain
9.7
Flexibility
7.6
Mobility
7.2
Mental/psychological
3.9
Dexterity
3.5
Hearing
3.2
Seeing
2.7
Memory
2.3
Learning
2.3
Developmental
0.6
Unknown
0.3

20. Employment and income: Just under half of Canadians with disabilities between 15 and 64 were employed, which is substantially below the rate for Canadians without disabilities (47% versus 74%). Unemployment increases substantially with the severity of the disability. For example, only around 26% of very severely disabled were employed as compared to 65% of those with mild disabilities. According to Statistics Canada estimates, the self-reported total median income of persons with disabilities is only around 2/3 of persons without disabilities ($20,000 versus $31,000). This gap increases sharply with the severity of the disability, with those that have severe and very severe disabilities reporting a median income that is less than half of Canadians without disabilities ($15,000 versus $31,000). This pattern is particularly acute for persons with disabilities of a working age (15-64). It is precisely because of this that MAC/Access 2020 Coalition propose that a commensurate portion of any aggregate funding mechanism that Commission adopts in this proceeding should be targeted to Canadians with severe and very severe disabilities with low or no income.

21. NDSF targeting and means testing: As noted, Canada has some of the highest prices in the world in terms of both fixed and mobile access. This makes it particularly challenging for persons with disabilities and low incomes to access the wide range of existing and emerging Internet applications that provide them with assistive, educational, social, and economic opportunities. To provide a first estimate of the cost of the proposed NDSF, consider the fact that around 14% of Canadians have some form of disability. Providing full or partial subsidies to this substantive proportion of the population would be obviously very expensive and potentially inefficient as the economic impact of disability on income is lower for persons with less severe disabilities and those with other means of financial support. Focusing on those with severe and very severe disabilities, which make up around 7% of the population, would still require substantive funding commitments. Using means testing based some measure of income would help target any potential funds to those who are most vulnerable. If individuals with severe and very severe disabilities are considered eligible for future affordability subsidies that have incomes below the median of $15,000 per year noted above for this sub-group, approximately 1 out of 4 Canadians with disabilities could potentially be eligible (around 3% of the population, or 1 million Canadians). Some proportion of this group will not necessarily take up the subsidies (e.g. vouchers distributed through social service organizations already working with the severe and very severely disabled), which means the actual number of target population the mechanism needs to cross-subsidize will likely be less than this benchmark.

22. Costing NDSF: Depending on the set of services CRTC ultimately includes in the basic service framework, the cost of covering even this very small and narrowly defined group of Canadians with disabilities will easily run into the hundreds of millions of dollars per year. Consequently, ensuring that basic communications services are affordable for our stakeholders will require a substantive increase in commitments by policymakers to the needs of Canadians with disabilities. For example, according to CRTC CMR data, average revenues for a fixed Internet service package with an advertised speed between 1.5-4 Mbps is currently around $50 per month (excluding modem rentals and other fees).[footnoteRef:4] A full $50 subsidy targeting very low income and severely disabled Canadians and reaching ½ of the 1 mil. persons who may be eligible under the means testing approach to NDSF noted above would require approximately $300 mil. per year, while a partial subsidy that covers only one half of the cost of basic service for this amount would be around $150 mil. per year. MAC/Access 2020 therefore submit that between $150 and $300 mil. would be needed to fund the narrowly focused need based NDSF mechanism required to extended affordable access to the Internet some of the most vulnerable Canadians with disabilities. Although we suspect that some parties to this proceeding who contend that market forces will address policy concerns about affordability of access may find this to be too expensive, MAC/Access 2020 stakeholders submit that the economic benefits extending affordable access to the most vulnerable members of our community will significantly outweigh its accounting costs. [4: CRTC CMR 2015. Table 5.3.6.] 23. Remaining gaps and tax credits: If the Commission chooses to define broadband access as a basic service, MAC/Access 2020 note that the targeted nature of NDSF will still leave significant gaps in affordable access to basic service for our stakeholders that would not necessarily be eligible for the funds from NDSF. Since only one quarter of the nearly 4 mil. Canadians with disabilities would qualify under the model sketched above, tax credits might be a viable option for enhancing the affordability of basic services for Canadians with disabilities with higher incomes. Even though tax policy is beyond the purview of the CRTC, we encourage the Commission to convey our message about this issue to Industry Canada and other federal policymakers. Access to reliable and affordable Internet connectivity can generate significant cost savings and quality improvements in the delivery of social services and healthcare to Canadians with disabilities. In this context, direct outlay through the NDSF and tax credits for accessing basic communications services could potentially lead to long term budgetary savings for federal, provincial, and municipal governments.

24. Market forces and access: Although ensuring all Canadians, including those with disabilities, have access to basic communications services will require a combination of subsidies and tax credits, we recognize the importance of policies that promote the incentives of private service providers to compete with each other to enhance affordability and quality of service they deliver. Unfortunately, in network industries such as telecom and broadcasting where a small number large providers dominate the provision of retail access, competitive discipline on pricing is often limited and affordability of access to vulnerable populations becomes a public policy concern. Consequently, MAC/Access 2020 Coalition support the Commission in its recent efforts to increase competition and investment in advanced fibre-to-the-premises (FTTP) technologies in the market for wholesale Internet access services. More wholesale market competition can provide some measure of pricing discipline and allow for service differentiation by multiple providers specialized in serving particular communities of end users with distinct needs, including Canadians with disabilities. Similarly, we strongly disagree with parties to this proceeding that argue there are no problems in the regulation of the retail market for fixed and mobile services that the Commission needs to or should solve by adopting policies that improve transparency of retail market transactions, accountability of dominant operators, and commitments of suppliers to deliver minimum actual service quality levels the Commission defines as basic in its determinations pursuant to this proceeding.

25. Market and regulatory transparency: The record of this proceeding is replete with debates between and evidence provided by large service providers and public interest consumer advocacy groups about gaps between advertised and actual speeds of connectivity in the Canadian market. Operators emphasize speeds they advertise and go on to say they are sufficient, while consumer groups demonstrate that actual speeds operators deliver can fall significantly below actual rates. Given the importance of service quality and reliability for deploying applications our stakeholders require, we submit that the Commission should use actual broadband network measurements, rather than indicators of advertised “best effort” speed, to evaluate the extent to which existing 5 Mbps down and 1 Mbps upload minimum speed targets are delivered during high traffic periods.

26. Beyond “best effort”: As detailed in our 1st intervention, access to reliable and affordable Internet connectivity represents a critical element of the ability of Canadians with disabilities to take part in social and economic activities. Over the past decade, a wide range of Internet applications have evolved that help enhance the quality of life and opportunities for persons with various types of disability. The ability of Canadians with disabilities to deploy these enabling applications depends on the availability of fixed and mobile broadband networks that are able to deliver high-speed and symmetric connections with minimum service quality guarantees. However, service providers in Canada only offer retail Internet access services in the residential market on a best effort basis (i.e. “up to xMbps). In our first submission, we conjectured that large service providers all have the technical capacity to use advanced network control technologies they utilize to differentiate service quality across end users and applications to deliver a basic service package that includes minimum service quality guarantees and meets the technical requirements of our stakeholders. This conjecture has now been confirmed on the record of this proceeding in responses by large operators to interrogatories by OpenMedia regarding the feasibility of mandating a minimum level of service quality guarantees for users that require more reliable basic services. Most of the large incumbents acknowledge that they have the technical capability of delivering such guarantees, and in fact many do so on demand for large customers for a price. However, the operators argue that they do not offer such guarantees to individuals and small businesses because of a purported lack of demand. Importantly, operators do not provide any evidence on the record that supports their contention about a lack of demand for service packages that deliver guaranteed minimum speeds across different application providers and over time. MAC/Access 2020 Coalition understands that the average user may not demand minimum service quality guarantees and might be satisfied with “best effort” service packages and uncertain levels of service. However, a wide range of advanced educational, assistive, and otherwise enabling applications that would improve the lives of our stakeholders require such guarantees for their reliable and safe utilization.

27. A standards-based approach to basic service: Given the technical feasibility of delivering minimum service guarantees and the significant reliability improvements they would involve relative to the current “best effort” offerings, in our original intervention MAC/Access 2020 Coalition recommended the Commission should mandate operators to offer at least one basic subscription package that offers service quality guarantees to end users whose particular needs require it. As we detailed in our first submission, this standard-based solution would minimize the potential for interference with market forces as the operators would be free to offer whatever “best effort” packages they want in addition to the basic service package the Commission mandates they should make available to any end user that requires minimum service guarantees. The fact that operators that dominate the Canadian retail market have acknowledged that they have already installed the necessary network control technologies, and in fact do deliver minimum guarantees of service quality on demand to business users, suggests that they can also do so for the rest of residential and business users requiring such basic guarantees from their access providers. We therefore reiterate our request in this proceeding to define a “basic service” package that includes such guarantees across content providers, applications, and at any time (e.g. 5/1 Mbps, 5/5 Mbps, or 10/10 Mbps if possible on fixed access; minimum service standards for mobile access could be lower due to technological differences). Our proposed approach would also help address concerns about traffic management/throttling policies that can slow access to Internet applications and content services our stakeholders require.

28. Retail market transparency, quality, and affordability: In contrast to the operators who argue market forces will solve all concerns (except perhaps in high-cost remote communities), the standards-based approach proposed above has the potential to enhance market forces in the provision of reliable and affordable basic services needed by all Canadians by making suppliers more accountable for the services they deliver. Reducing uncertainties about service quality would be to the advantage of operators that invest more in achieving service levels they have promised their customers in retail contracts by enabling end users who require service quality guarantees to opt out of the “best effort” market. Since large operators already have installed network control technologies that enable them to offer such guarantees, adopting our proposal is likely to require little additional investment for them.[footnoteRef:5] While the evidence on the record of this proceeding clearly illustrates that it is feasible to implement our recommendation about mandating at least one package with service quality guarantees with minimal cost, questions about the price at which operators would have to sell this basic service package, minimum standards of service to be incorporated, and how can customers verify actual service quality will have to be considered; that is if, as we hope, the Commission chooses to redefine high-speed access as a basic service and adopt the approach we have proposed. [5: Please note this may not be the case for smaller operators who have not yet invested in advanced network control and traffic flow differentiation technologies.] 29. Verification of minimum basic service standards: The 5/1 Mbps minimum service objectives the Commission adopted in 2011 have been interpreted as “aspirational” targets large broadband operators than 90% of Canadians. These parties continue to maintain that the Commission should continue with the same approach by keeping “aspirational” standards, rather than adopting hard and verifiable minimum service quality standards. The fact that operators are very reluctant to estimate and disclose what proportion of connections that they deliver to end users fall below or above the 5/1 Mbps minimum service levels the CRTC adopted years ago underscores the importance of verification and hard targets in redefining high-speed Internet access as a basic service under the Telecommunications Act. If the Commission chooses to redefine broadband as a basic service essential to the needs of all Canadians, then MAC/Access 2020 Coalition submits it should also adopt a standardized mechanism that enables each end user to verify if they are getting the speeds either as advertised (in case they are on a “best effort” plan) or minimum guaranteed (in case they are on a basic plan with minimum service guarantees) speeds they have been promised by their service provider. The SamKnows approach to speed testing adopted by the Commission in agreement with dominant service providers is a closed testbed limited to selected participants, and therefore does not allow our stakeholders or other Canadians that are not part of the SamKnows testbed to verify what they are getting from their network operators. Instead, we recommend the Commission adopt the testbed that has recently been deployed by the Canadian Internet Registration Authority (CIRA) as a tool for enabling any end user to verify the quality of service using a standards-based methodology provided by a relatively independent third party.[footnoteRef:6] In addition to being open to any customer to use, the CIRA Internet Performance **** (IPT) provides various metrics to end users and regulatory authorities that help identify if causes for unreliable and low quality services can be attributed to end user equipment shortcomings or congestion/under-provisioning by their network provider. The results of the CIRA IPT can provide valuable evidence to the CRTC, CCTA, or in the courts in case of misleading advertising claims, if and when particular operators oversell their capacity (i.e. under-invest) and therefore fail to meet the service quality levels they have promised to customers or minimum standards for basic service as mandated by the Commission at the conclusion of this proceeding. [6: https://cira.ca/performance ] 30. Disabilities Rights Office (DRO): Our proposal for a DRO in MAC/Access 2020’s first submission remains unique and none of the parties have provided any evidence or arguments opposing our proposal regarding the establishment of a DRO at the CRTC with the mandate to provide a disabilities perspective on access, service quality, and affordability and to enable our stakeholders to communicate with service providers in a constructive manner. Since our fist submission in this proceeding, we were pleased to have the opportunity to participate in the CRTC 2015-239 proceedings regarding the structure and mandate of the Commissioner for Complaints for Telecommunications Services Inc. (CCTS) and discuss various options with the Commission for setting up a DRO at the CRTC. We were particularly pleased that Commissioner **** found that we have presented “a fairly well-formed call for a DRO” as part of the CCTS review process.[footnoteRef:7] We urge the Commission to build on our proposal as soon as possible, either as part of its forthcoming decision regarding the CCTS review, as part of this proceeding on the availability of basic services to all Canadians, or to initiate a separate proceeding focusing on the structure and mandate of a DRO at the CRTC. MAC/Access 2020 Coalition reiterates our willingness to help the CRTC set up an effective DRO and engage with service providers to improve their capacity to accommodate basic customer service and dispute resolution needs of Canadians with disabilities. We submit that the question of a DRO is within the scope of both CRTC 2015-239 and CRTC 2015-134 proceedings. MAC/Access 2020 Coalition strongly believe in the importance of a DRO for improving accessibility of basic services to our stakeholders, reducing the costs to service providers of serving Canadians with disabilities, and encouraging operators to care more about the basic communications needs of Canadians with disabilities for access to services they consider essential. Although it is not really relevant which of the proceedings the Commission utilizes to respond to demands by our stakeholders for a DRO, we hope that it takes action on this important issue to Canadians with disabilities as soon as possible. [7: CRTC 2015-239 transcript, Vol. 2, paragraph 1656.] 31. From specialized services to basic broadband access: Over the past few years, the CRTC has increasingly recognized that market forces often fail to meet the needs of Canadians with disabilities and that innovative policy solutions are necessary. This basic service proceeding has generated further questions by the Commission and various parties about the relevance of defining specialized services such as Video Relay Service (VRS) as a basic service under the Telecommunications Act. Operators who oppose adoption of basic service obligations on high-speed fixed and mobile data access have also opposed making specialized services such as VRS a basic service. For example, in response to an RFI from the Commission, Shaw concedes that “specialized telecommunications services like Message Relay Service, IP Relay and Video Relay Service (VRS) enable Canadians with disabilities to access and participate in the digital economy”, but goes on to contend that “However, Shaw does not consider it necessary to incorporate VRS in the basic service objective.”[footnoteRef:8] On the other hand, the Canadian Hearing Society highlights that “VRS will provide functional equivalency to telephone services for Deaf and hard of hearing consumers” and therefore should be defined as a basic service.[footnoteRef:9] MAC/Access 2020 Coalition agree with the position of the Canadian Hearing Society regarding the status of the specialized and centrally administered VRS service that is currently under development. Furthermore, we think it is important to reiterate the point emphasized by the Deaf Wireless Canada Committee that the utilization of specialized services such as the VRS and other IP based applications can have a significant impact on the data usage of Canadians with disabilities on both fixed and mobile service plans.[footnoteRef:10] Lower than expected connectivity speeds, data caps, excessive use overcharges and throttling of service above a certain usage threshold limit reliability and affordability of specialized services designed for the disabilities community. These realities of the market can have a large negative impact on the ability of Canadians with disabilities to deploy specialized services such as VRS, as well as the wide variety of other network-intensive applications and services that have emerged on the global market to serve the needs of persons with disabilities. Competition and innovation in the global market for applications that serves our needs provides a range of new tools that help enable our members to engage in social and economic activities. It is precisely for this reason that MAC/Access 2020 submits the Commission should define both fixed and mobile high-speed Internet data access as a basic service and should adopt a standards-based approach to achieving its basic service objectives. [8: Responses to Request for Information by the CRTC from Shaw, 2 November 2015, page 1.] [9: Response to Request for Information by the CRTC from the Canadian Hearing Society, 27 November 2015.] [10: Responses to Request for Information by the CRTC from the Deaf Wireless Canada Committee, 21 November 2015.] 32. [bookmark: _GoBack][bookmark: KVWin_undoend]Accessible services and wireless handsets: The CRTC basic services regulatory framework must include access to wireless telecommunication services for all Canadians with disabilities. We believe this should include, for example: text messaging, e-mail, instant messaging, and video communications” as is similarly required under US regulation[footnoteRef:11]. To ensure all users can take advantage of these services, we submit the Commission should clarify Broadcasting and Telecom Regulatory Policy CRTC 2009-430 in relation to: “offer at least one mobile handset for persons who are blind and/or have moderate to severe mobility or cognitive disabilities” to clearly define ”moderate” and “severe” so that it is clear what type of functional limitations need to be addressed to meet those individuals who fall into these categories particularly those with severe mobility disabilities. In addition, we submit that telephone providers not only must offer a bona fide accessible mobile handset for these individuals but they must also provide support to these individuals so they can appropriately select and then set up the handset in such a way that it works effectively for them. [11: As similarly defined under the Twenty-First Century Communications and Video Accessibility Act of 2010 (https://www.fcc.gov/encyclopedia/twenty-first-century-communications-and-video-accessibility-act-0 ).] Appendix: MAC/Access 2020 Coalition stakeholder replies to

the basic services consultations

“My opinion, doubtless endorsed by most blind people, is that on top of the time consumed for a screen reader and a print enlarger to organize and deliver a screen full of information, the time necessary to deliver that screen can only make browsing more slow and tedious. While certain modes of video compression keep important elements of the screen which don't change, for redelivery, screen reading technology interrogates the entire screen for any change. Hence, there is no time. Decrease in the use of partial refills.” “It's obvious that the seeing user desires…. higher speeds, and there is no reason to believe that low vision or blind people have any less desire. In simple terms, the compounding complexity of screen readers with slow data speed, prolongs the waiting.”“A part of blindness seldom discussed, is boredom. **** people cannot easily look around the room at pictures on the wall, or out the window to see the birds in the trees, or doodle. So one may daydream, scheme, or count the ticks of the clock. Hence, quick data recovery can make one's Internet experience much more comfortable.”“Unemployed and retired blind people have found a whole new world of interest, adventure, and purpose in their computing devices, and like their seeing peers, many spend the whole day reading newspapers, in audio chat rooms, on list serves, on Facebook, on twitter, and listening to audio streams of recorded materials, frequently with description.”“Communities of blind people, like their seeing peers, on the Internet trade audio from their DVD collections, especially items with DVS tracks. These audio files can be 1 to 200 MB, even when compressed, and downloading can take time. Downloading tends to be preferred as streaming can be inconsistent at times of Internet congestion or server failure.”“Also, blind people packed material onto portable MP3 type players or their phones to listen while traveling, waiting in doctors offices, or relaxing on the deck. Remember now, writing in the car or on the bus can be incredibly boring because one cannot people watch or look out the window.”“Please do not accept these latter comments is gratuitous, as I thought it important for you to understand how easily captured audio can be a main prop in upholding one's peace of mind and life interest. While library books are all well and good, blind people like to stay in tune with all aspects of modern culture, and these days for blind people, much of that comes from the Internet. It goes without saying that this should be made possible without complications and consuming the least time possible.”“At home, or when visiting, and a movie is being shared, conversation goes on with the odd pause for an exciting moment. As you would appreciate, conversation drowns out the movie, both by volume, and often by interesting content. Clearly, without a visual path, one must totally concentrate on the audio: voices, sound effects, and possible description, to follow. Movies often have complicated plots with nearly simultaneous scenes and or time shifts, and everyone knows what that's like. Without a rewind function. So my mode, is to find the audio description recording out there, and play it back to myself with total control of volume, fast forward, and rewind. For me, at least, conversation in a movie doesn't work.”“The podcast world has become so rich that it takes more of my entertainment time every day. While YouTube is very interesting, I get a great deal of material that has been described from my British colleagues who extract it and post it online to an exclusive user group. Believe me, send space is our friend.” “Noting above the predilection of some blind people to consume audio only, for blind people living alone, one could argue that they are paying for a major component of the service that they cannot use. Hence, a specialty economy connection option makes good sense.”“Don’t know how much national attention this attempt to cap Internet broadband in rural areas is getting, but I figured you should know about what we are being told. This fee increase by Eastlink is going to create, and continue to enforce – a second class of telecommunication users.

(That is, those users in rural areas, whether they are disabled or abled.) It is very strange that people in urban centres - or rurally in other provinces - do not use Netflix and/or do the same streaming as those in rural Nova Scotia do.”

“And it also irks me considerably that …… a spokesman for Seaside Wireless Communications could come out and say that the Broadband for Rural Nova Scotia program was “a pretty visionary project.” That speed was merely what all telecommunications suppliers/sellers were supposed to be doing! And as a former journalist and now a communications consultant, he should know that. The upgrade that Seaside Wireless is embarking on – with federal help – is just bringing them up to speed ... to the minimum of what they should be providing.”Comments collected from a town hall meeting of MAC/Access 2020 Stakeholders to discuss their access to basic communications service. Participants included cognitive, hard of hearing, low vision, senior, and other members of our community.

· One **** station across Canada, on all cable programming
· TV guide not on cable TV not useful for people with disabilities - electronic television listing
· People with acquired brain injury struggle with estimating data, voice usage, etc., not only brain injury but everyone
· Free long distance education, who pays for it, get 1100 free online courses from online universities (iv league), download them even from YouTube, 30,000 hours of free lectures - free long distance education
· Free online webinars
· Funded infrastructure - should be available for everyone
· All basic telecom infrastructure should be reviewed
· Digital literacy, cap sites in Nova Scotia, to improve digital literacy for everyone in the community including the disabled

· The balance between freedom of action and freedom of speech and access to service, difficult balance, if we can't run this program (cap) and prevent the bad elements from outweighing the good, then we'll cancel it - still exists in nova scotia but not elsewhere· Almost every library has problems with this, not always in libraries either - open access computers, hard to supervise

· Lack of usage for cap in sask, we had it, it was free but nobody would use it, most people would go to the Y or the library and pay for computer lessons
· High cost service areas where 5 mbps down and 1 mbps up, you're only as good as your weakest link
· Remote areas, sask, bc, mb, nova scotia too, many places with no coverage because of geography, nova scotia should be included in the list of remote places where coverage is poor

· Telehealth is not used to broadcast meetings across the province because of confidentiality, but in hospitals they have monthly meetings in Halifax but only if you attend the meeting in person but they don't have them broadcast online, they say it's because of confidentiality· Recently a major accessibility issue because most of the provincial services are going to 1800 numbers but people with cell phones that do not have a plan can only text, we bought a cell phone at one clinic so that we could receive text, deaf text only as well, going to only 1800 numbers will lose all the people who text or are below the low income cut off and cannot afford a cell plan. conversely I wouldn't want everything to go to text since some people don't have cell phones, not a single point of entry or communication, we need multiple avenues, if I cannot call the welfare office I should be able to email, text or visit them in person· Transition article - digital immigrant - person applying for welfare was given a piece of paper with a website address to apply for welfare

· Not only people with disabilities, this benefits everybody

· 2009, CP Saskatoon, applied and rejected from Canadian paraplegic in sask discounted cell phone if you get a membership to CP assoc, neurologic condition, qualifications are CP, company gave sponsorship deal with CPA, not CP but neurological disability, if you aren't a paraplegic why would I think to become a member, it's not really any cheaper than getting a cell phone from most companies anyways· Even with all the monthly fees, the cell phone expense and programs and internet and computer are very expensive to purchase, getting all three packages a month is very costly, people who are low income cannot afford it

· If you are on social assistance, connectivity is never seen as a necessity of life, this is a mistake, people who are low income need this, kids learn from tv and internet now, this should be necessities
***End of Document***
20

Further Comments : Media Access Canada / Access 2020

Document Name: 2015-134.223960.2530446.Further Comments (1$8$601!).html

Raisons pour comparaitre / Reasons for appearanceOur intervention is submitted on the basis of input received from a variety of organizations representing persons with disabilities in Canada. The needs of one are not necessarily the needs of all, and having a variety of perspectives, including the personal experiences of individuals with disabilities, are important to the exercise of the Commission's direction.

Further Comments : Media Access Canada (Intervenor 693)

Document Name: 2015-134.223960.2530446.Further Comments (1$8$601!).html

Raisons pour comparaitre / Reasons for appearanceOur intervention is submitted on the basis of input received from a variety of organizations representing persons with disabilities in Canada. The needs of one are not necessarily the needs of all, and having a variety of perspectives, including the personal experiences of individuals with disabilities, are important to the exercise of the Commission's direction.