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Letter

Ottawa, 7 August 2008

File No. 8665-C12-200807943

By email

To:   Distribution List (attached)

Re:  Unresolved issues related to the accessibility of telecommunications and broadcasting services for persons with disabilities, Broadcasting Notice of Public Hearing CRTC 2008-8 and Telecom Public Notice CRTC 2008-8 (Notice)

Pursuant to the procedures specified at paragraph 24 of Unresolved issues related to the accessibility of telecommunications and broadcasting services for persons with disabilities , Broadcasting Notice of Public Hearing CRTC 2008-8 and Telecom Public Notice CRTC 2008-8, 10 June 2008, as amended by Commission staff letter dated 2 July 2008, attached is the second round of questions associated with this proceeding.

Parties are requested to file their responses with the Commission by 5 September 2008 .   These responses are to be received, and not merely sent, by this date.   In providing responses, parties are requested to take into consideration all of the company's relevant operations in telecommunications and broadcasting.

It is noted that a number of telecommunications service providers, broadcasters and broadcasting undertakings have not submitted a response to the first round of questions.   Commission staff notes that, as set out in paragraph 11 of the Notice, as a result of this proceeding, the Commission could impose additional obligations on some or all telecommunications service providers and broadcasting undertakings.

Parties may contact Jennifer Eustace (jennifer.eustace @crtc.gc.ca) at 819-997-1328 should they have any questions in regard to this process.

  • Attachment 1 contains the distribution list for the questions.
  • Attachment 2 contains the second round of questions.

 

Yours sincerely,

Original signed by

 

Kathleen Taylor
Project Manager
Social Policy

 

Attach:   Attachments 1 and 2





ATTACHMENT 1

SECOND ROUND OF QUESTIONS

QUESTIONS TO

A) ILECS
•  Bell Aliant Regional Communications, Limited Partnership
•  Bell Canada
•  MTS Allstream Inc.
•  Northwestel Inc.
•  SaskTel
•  Télébec, Limited Partnership
•  TELUS Communications Company

B) CLECS
•  Access Communications Co-operative Limited
•  Bragg Communications Incorporated (EastLink)
•  Cable-Axion Digitel Inc.
•  Cogeco Cable Canada Inc.
•  Distributel Communications Limited
•  ExaTEL Inc.
•  Fido Solutions Inc.
•  Globility Communications Corporation
•  Iristel Inc.
•  ISP Telecom Inc.
•  IVIC Télécom s.e.n.c. (IVIC Internet)
•  Maskatel Inc.
•  Mountain Cablevision Ltd.
•  Persona Communications Corp.
•  Rogers Cable Communications Inc.
•  Shaw Telecom Inc.
•  Téléphone Drummond Inc.
•  TelNet Communications
•  Vidéotron Ltd.

C) BDUS
•  Access Communications Co-operative Ltd.
•  Bell Canada
•  Bragg Communications Inc.
•  Cable-Axion Digitel Inc.
•  Cogeco Inc.
•  Mountain Cablevision Inc.
•  MTS Allstream Inc.
•  Rogers Communications Inc.
•  SaskTel
•  Shaw Communications Inc.
•  Star Choice Communications Inc.
•  TELUS Communications Company
•  Quebecor Media Inc.
•  Canadian Cable Systems Alliance Inc.

D) BROADCASTERS
•  Astral Media Inc.
•  Canadian Broadcasting Corporation
•  Canwest Media Inc.
•  Corus Entertainment Inc.
•  CTVglobemedia Inc.
•  Quebecor Media Inc.
•  Rogers Broadcasting Limited
•  TQS Inc.
•  Cogeco Diffusion Inc.
•  Corus Radio Company
•  Golden West Broadcasting Ltd.
•  Jim Pattison Broadcast Group Limited Partnership
•  Maritime Broadcasting System Limited
•  Newcap Inc.
•  Rawlco Radio Ltd.

E) ORGANISATIONS REPRESENTING PERSONS WITH DISABILITIES
•  Alliance for Equality of Blind Canadians
•  Arch Disability Law Centre
•  Canadian Association of the Deaf / Association des Sourds du Canada
•  Canadian Council of the Blind / Conseil canadien des aveugles
•  Canadian Hard of Hearing Association in Hamilton / Association des malentendants canadiens à Hamilton
•  Canadian Hearing Society / Société canadienne de l'ouÏe
•  Ryerson Centre for Learning Technologies
•  Centre québécois de la déficience auditive
•  Citizens with Disabilities - Ontario
•  CNIB / INCA
•  Council of Canadians with Disabilities / Conseil des canadiens avec deficiencies
•  National Broadcast Reading Service Inc.
•  Neil Squire Society / Société Neil Squire
•  Regroupement des aveugles et amblyopes du Québec
•  Sorenson Communications of Canada, ULC
•  VRS Consultative Committee of BC

F) ORGANISATIONS REPRESENTING PERSONS WITH DISABILITIES RELATED TO HEARING
•  Arch Disability Law Centre
•  Canadian Association of the Deaf / Association des Sourds du Canada
•  Canadian Hard of Hearing Association in Hamilton / Association des malentendants canadiens à Hamilton
•  Canadian Hearing Society / Société canadienne de l'ouÏe
•  Centre québécois de la déficience auditive
•  Citizens with Disabilities - Ontario
•  Council of Canadians with Disabilities / Conseil des canadiens avec deficiences
•  Neil Squire Society / Société Neil Squire
•  VRS Consultative Committee of BC

G) BELL CANADA

H) THE NEIL SQUIRE SOCIETY

I) ARCH DISABILITY LAW CENTRE

J) THE COUNCIL OF CANADIANS WITH DISABILITIES

K) THE VRS CONSULTIVE COMMUNITY OF BC

 

 

 

 


ATTACHMENT 2

A) QUESTIONS TO ILECS

QUESTION 1: At paragraph 68 of its 10 July comments, the VRS Consultative Committee of BC proposed the establishment of a system whereby persons who are Deaf, Deafened or hard of hearing could contact emergency services (i.e. 9-1-1 ) via text messaging.

Indicate any barriers, technical or otherwise, that would, in your Company's view, prevent PSAPs from becoming equipped to receive and respond to text messages. Indicate any technical or other solutions you are aware of that could assist PSAPs in becoming equipped to receive and respond to text messages.

QUESTION 2: In Bell Canada(CRTC)10Jun08-100 Attachment 2, Bell Canada submitted a report by the PELORUS Group, which stated (page 14) that, in the U.S., speech recognition technology is being used to enhance traditional TTY by significantly increasing the flow of conversations (by partially automating the Call Assistant (CA) function).

Indicate whether your Company currently partially automates the CA function on TTY calls. Alternatively, indicate any barriers that prevent you from undertaking to partially automate TTY calls toward the goal of improving this service.

QUESTION 3: At paragraph 9 of its 24 July 08 comments, the Neil Squire Society stated: "the US Federal Communications Commission has rules requiring TSPs to make their products and services accessible to people with disabilities, if such access is readily achievable.Where access is not readily achievable, Section 255 (Communications Act) requires manufacturers and service providers to make their devices and services compatible with peripheral devices and specialized customer premises equipment that are commonly used by people with disabilities, if such compatibility is readily achievable."

Comment on the appropriateness of the CRTC establishing similar rules for TSPs.

QUESTION 4: Several disability advocacy groups submitted that persons with disabilities need information, in formats they can use, on what terminal equipment is available that could give them equivalent access to their TSPs' services. These groups also argued that if such information exists and is available (in multiple formats), TSPs are not sufficiently promoting the availability of such information.

a) Describe measures taken by your Company to produce and promote information on terminal equipment which would enable persons with disabilities to achieve equivalent access to your telecommunications services. This might be equipment your Company offers that is compatible with your services or such equipment that is available elsewhere, with information about how to obtain it. List the promotional methods used (e.g. bill inserts), as well as the frequency and duration of such promotions. Also, identify any use of alternate formats to promote such information (e.g. providing such information in Braille to customers who request their bills in Braille).

b) A party to the proceeding submitted that the Commission should publish an annual report on the accessibility of TSPs services.

Assume the CRTC were to publish an annual report on the accessibility of services offered by TSPs. Comment on the appropriateness of such a report and/or provide an alternative solution to address concerns about the availability of information on what terminal equipment is available that could give people with disabilities equivalent access to their TSPs' services.

c) At paragraphs 49-50 of its 25 July revised comments, ARCH submitted that "the Commission must establish reporting requirements for implementing all accessibility initiatives required by the present proceeding. These reports must be available to the public."

The Australian telecommunications company Telstra has developed several Disability Action Plans since 1996.   It has made publicly available reports on its progress in achieving the commitments made in its action plans to promote accessibility.   These action plans deal with a wide variety of issues, including the accessibility of Telstra's buildings and facilities, the accessibility of information, the accessibility of Telstra's new and existing products and services, and discrimination in the workplace. (Action plans and reports are available at   http://www.telstra.com.au/disability/action_plan.htm .)

Should all industry service providers be required to submit such action plans and reports?   Provide full justification for your position.   If so, what information should be included and how often should the reports be submitted?

d) A party to the proceeding recommended that all TSPs publish a pamphlet outlining service amenities for persons with disabilities.

Assume the CRTC accepted this recommendation. Indicate your Company's view on the appropriate information to be included, the frequency of distribution, distribution by mail, and publishing/updating the pamphlet on your website.

e) In paragraph 128 of its 25 July revised comments, ARCH suggested that the Commission require TSPs to make the Statement of Consumer Rights available in more alternative formats, for example, American Sign Language (ASL) and Langue de Signes Québécoise (LSQ) videos.

Indicate whether your Company's Statement of Consumer Rights is currently available to your customers in an ASL or LSQ video. If not, indicate whether your Company intends to make your Company's statement of Consumer Rights available in such formats a) upon request and/or b) on your website in the future. If so, indicate when your Company anticipates those formats will be available.  

QUESTION 5: Disability advocacy groups and Bell Canada (Bell Canada(CRTC)10Jun08-100) identified the lack of service packages or customized options tailored for persons with disabilities as a difficulty for persons with disabilities in achieving equal access to telecom services.

Describe any service packages or customized options your Company provides that are tailored for persons with disabilities (i.e. as opposed to packages that could address the needs of persons with disabilities without being designed to specifically address such needs) with respect to the your telecommunications service offerings. List any packages by type of disability: a) sight, b) hearing, c) speech, d) mobility and agility, e) cognition , f) other. See, for example, the AT+T "Data Plan" described at paragraph 43 of Appendix A to the comments of the Canadian Association of the Deaf.

QUESTION 6: Many TSPs indicated that they receive few complaints related to accessibility. However, disability advocacy groups indicated that there is significant concern among persons with disabilities about the current and future accessibility of telecommunications services.

List the means (i.e. telephone, TTY, W3C compatible web site) by which consumers can submit concerns and suggestions about the accessibility of your services. List the ways you promote the availability of such complaint mechanisms to your customers or describe the barriers that prevent you from doing so.

QUESTION 7: In Bell Canada(CRTC)10Jun08-100 Attachment 2, Bell Canada submitted a report by the PELORUS Group which stated (page 12) that in the U.S. providers of relay services are compensated via a fund managed by the FCC (the National Exchange Carrier Association fund). Further, relay services are funded by a surcharge on all users' telephone bills.

Assume the CRTC were to determine that it was appropriate that VRS be available nationally. Assume the CRTC were to examine the viability of establishing a similar funding mechanism for the future provision of VRS. Indicate whether the establishment of a similar fund would be an appropriate source of funding for VRS or propose alternative sources of funding. Propose solutions to address any competitive inequalities that could result from the previous allocation of deferral account funds toward the provision of territory-specific VRS.

QUESTION 8: P rovide your Company's views, with full justification, as to whether or not all industry service provider websites should be W3C-compliant.

QUESTION 9: Provide your views, with full details and justification, on the elements of a meaningful and effective ongoing consultation process between industry service providers and disability groups.   Should such consultations be required and, if so, why and by what means?

QUESTION 10: What questions should be answered in any disability impact statement?   Provide full details and justification.

 

B) QUESTIONS TO CLECS

QUESTION 1: Provide your views, with full justification, on the appropriateness of extending all ILEC accessibility-related obligations (e.g. 50 percent discount for long distance calls by TTY users, free directory assistance and call completion assistance) to all TSPs.

QUESTION 2: At paragraph 9 of its 24 July 08 comments, the Neil Squire Society stated: "the US Federal Communications Commission has rules requiring TSPs to make their products and services accessible to people with disabilities, if such access is readily achievable.Where access is not readily achievable, Section 255 (Communications Act) requires manufacturers and service providers to make their devices and services compatible with peripheral devices and specialized customer premises equipment that are commonly used by people with disabilities, if such compatibility is readily achievable."

Comment on the appropriateness of the CRTC establishing similar rules for TSPs.

QUESTION 3: Several disability advocacy groups submitted that persons with disabilities need information, in formats they can use, on what terminal equipment is available that could give them equivalent access to their TSPs' services. These groups also argued that if such information exists and is available (in multiple formats), TSPs are not sufficiently promoting the availability of such information.

a) Describe measures taken by your Company to produce and promote information on terminal equipment which would enable persons with disabilities to achieve equivalent access to your telecommunications services. This might be equipment your Company offers that is compatible with your services or such equipment that is available elsewhere, with information about how to obtain it. List the promotional methods used (e.g. bill inserts), as well as the frequency and duration of such promotions. Also, identify any use of alternate formats to promote such information (e.g. providing such information in Braille to customers who request their bills in Braille).

b) A party to the proceeding submitted that the Commission should publish an annual report on the accessibility of TSPs services.  

Assume the CRTC were to publish an annual report on the accessibility of services offered by TSPs. Comment on the appropriateness of such a report and/or provide an alternative solution to address concerns about the availability of information on what terminal equipment is available that could give people with disabilities equivalent access to their TSPs' services.

c) At paragraphs 49-50 of its 25 July revised comments, ARCH submitted that "the Commission must establish reporting requirements for implementing all accessibility initiatives required by the present proceeding. These reports must be available to the public."

The Australian telecommunications company Telstra has developed several Disability Action Plans since 1996.   It has made publicly available reports on its progress in achieving the commitments made in its action plans to promote accessibility.   These action plans deal with a wide variety of issues, including the accessibility of Telstra's buildings and facilities, the accessibility of information, the accessibility of Telstra's new and existing products and services, and discrimination in the workplace. (Action plans and reports are available at   http://www.telstra.com.au/disability/action_plan.htm .)

Should all industry service providers be required to submit such action plans and reports?   Provide full justification for your position.   If so, what information should be included and how often should the reports be submitted?

d) A party to the proceeding recommended that all TSPs publish a pamphlet outlining service amenities for persons with disabilities.

Assume the CRTC accepted this recommendation. Indicate your Company's view on the appropriate information to be included, the frequency of distribution, distribution by mail, and publishing/updating the pamphlet on your website.

e) In paragraph 128 of its 25 July revised comments, ARCH suggested that the Commission require TSPs to make the Statement of Consumer Rights available in more alternative formats, for example, American Sign Language (ASL) and Langue de Signes Québécoise (LSQ) videos.

Indicate whether your Company's Statement of Consumer Rights is currently available to your customers in an ASL or LSQ video. If not, indicate whether your Company intends to make your Company's statement of Consumer Rights available in such formats a) upon request and/or b) on your website in the future. If so, indicate when your Company anticipates those formats will be available.  

QUESTION 4: Disability advocacy groups and Bell Canada (Bell Canada(CRTC)10Jun08-100) identified the lack of service packages or customized options tailored for persons with disabilities as a difficulty for persons with disabilities in achieving equal access to telecom services.

Describe any service packages or customized options your Company provides that are tailored for persons with disabilities (i.e. as opposed to packages that could address the needs of persons with disabilities without being designed to specifically address such needs) with respect to the your telecommunications service offerings. List any packages by type of disability: a) sight, b) hearing, c) speech, d) mobility and agility, e) cognition , f) other. See, for example, the AT+T "Data Plan" described at paragraph 43 of Appendix A to the comments of the Canadian Association of the Deaf.

QUESTION 5: Many TSPs indicated that they receive few complaints related to accessibility. However, disability advocacy groups indicated that there is significant concern among persons with disabilities about the current and future accessibility of telecommunications services.

List the means (i.e. telephone, TTY, W3C compatible web site) by which consumers can submit concerns and suggestions about the accessibility of your services. List the ways you promote the availability of such complaint mechanisms to your customers or describe the barriers that prevent you from doing so.

QUESTION 6: In Bell Canada(CRTC)10Jun08-100 Attachment 2, Bell Canada submitted a report by the PELORUS Group which stated (page 12) that in the U.S. providers of relay services are compensated via a fund managed by the FCC (the National Exchange Carrier Association fund). Further, relay services are funded by a surcharge on all users' telephone bills.

Assume the CRTC were to determine that it was appropriate that VRS be available nationally. Assume the CRTC were to examine the viability of establishing a similar funding mechanism for the future provision of VRS. Indicate whether the establishment of a similar fund would be an appropriate source of funding for VRS or propose alternative sources of funding. Propose solutions to address any competitive inequalities that could result from the previous allocation of deferral account funds toward the provision of territory-specific VRS.

QUESTION 7: P rovide your Company's views, with full justification, as to whether or not all industry service provider websites should be W3C-compliant.

QUESTION 8: Provide your views, with full details and justification, on the elements of a meaningful and effective ongoing consultation process between industry service providers and disability groups.   Should such consultations be required and, if so, why and by what means?

QUESTION 9: What questions should be answered in any disability impact statement?   Provide full details and justification.

 

C) QUESTIONS TO BDUS

QUESTION 1: Several disability advocacy groups submitted that persons with disabilities need information, in formats they can use, on what customer equipment is available that could give them equivalent access to broadcasting services. These groups also argued that if such information exists and is available (in multiple formats), service providers are not sufficiently promoting the availability of such information.

a) Describe measures taken by your Company to produce and promote information on customer equipment which would enable persons with disabilities to achieve equivalent access to your services. This might be equipment your Company offers that is compatible with your services or such equipment that is available elsewhere, with information about how to obtain it. List the promotional methods used as well as the frequency and duration of such promotions. Also, identify any use of alternate formats to promote such information.

b) A party to the proceeding submitted that the Commission should publish an annual report on the accessibility of broadcasting services.

Assume the CRTC were to publish an annual report on the accessibility of services. Comment on the appropriateness of such a report and/or provide an alternative solution to address concerns about the availability of information on what terminal equipment is available that could give people with disabilities equivalent access to broadcasting services.

c) At paragraphs 49-50 of its 25 July revised comments, ARCH submitted that "the Commission must establish reporting requirements for implementing all accessibility initiatives required by the present proceeding. These reports must be available to the public."

The Australian telecommunications company Telstra has developed several Disability Action Plans since 1996.   It has made publicly available reports on its progress in achieving the commitments made in its action plans to promote accessibility.   These action plans deal with a wide variety of issues, including the accessibility of Telstra's buildings and facilities, the accessibility of information, the accessibility of Telstra's new and existing products and services, and discrimination in the workplace. (Action plans and reports are available at   http://www.telstra.com.au/disability/action_plan.htm.)  

Should all industry service providers be required to submit such action plans and reports?   Provide full justification for your position.   If so, what information should be included and how often should the reports be submitted?

d) A party to the proceeding recommended that all broadcasting undertaking publish a pamphlet outlining service amenities for persons with disabilities.

Assume the CRTC accepted this recommendation. Indicate your Company's view on the appropriate information to be included, the frequency of distribution, distribution by mail, and publishing/updating the pamphlet on your website.

QUESTION 2: P rovide your Company's views, with full justification, as to whether or not all industry service provider websites should be W3C-compliant.

QUESTION 3: Provide your views, with full details and justification, on the elements of a meaningful and effective ongoing consultation process between industry service providers and disability groups.   Should such consultations be required and, if so, why and by what means?

QUESTION 4: What questions should be answered in any disability impact statement?   Provide full details and justification.

 

D) QUESTIONS TO BROADCASTERS

QUESTION 1: P rovide your Company's views, with full justification, as to whether or not all industry service provider websites should be W3C-compliant.

QUESTION 2: Provide your views, with full details and justification, on the elements of a meaningful and effective ongoing consultation process between industry service providers and disability groups.   Should such consultations be required and, if so, why and by what means?

QUESTION 3: A party to the proceeding submitted that the Commission should publish an annual report on the accessibility of broadcasting services. At paragraphs 49-50 of its 25 July revised comments, ARCH submitted that "the Commission must establish reporting requirements for implementing all accessibility initiatives required by the present proceeding. These reports must be available to the public."

Assume the CRTC were to publish an annual report on the accessibility of services. Comment on the appropriateness of such a report and/or provide an alternative solution to address concerns about the availability of information on what terminal equipment is available that could give people with disabilities equivalent access to broadcasting services.

 

E) QUESTIONS TO ALL ORGANSATIONS REPRESENTING PERSONS WITH DISABILITIES

Question 1: The Australian telecommunications company Telstra has developed several Disability Action Plans since 1996.   It has made publicly available reports on its progress in achieving the commitments made in its action plans to promote accessibility.   These action plans deal with a wide variety of issues, including the accessibility of Telstra's buildings and facilities, the accessibility of information, the accessibility of Telstra's new and existing products and services, and discrimination in the workplace. (Action plans and reports are available at   http://www.telstra.com.au/disability/action_plan.htm.)

Should all industry service providers be required to submit such action plans and reports?   Provide full justification for your position.   If so, what information should be included (for the broadcasting industry and the telecommunications industry) and how often should the reports be submitted?

QUESTION 2: Provide your views, with full details and justification, on the elements of a meaningful and effective ongoing consultation process between industry service providers and disability groups.   Should such consultations be required and, if so, why and by what means?

QUESTION 3: What questions should be answered in any disability impact statement?   Provide full details and justification.

 

F) QUESTIONS TO ORGANISATIONS REPRESENTING PERSONS WITH DISABILITIES RELATED TO HEARING:

QUESTION 1: In Bell Canada(CRTC)10Jun08-100 Attachment 2, Bell Canada submitted a report by the PELORUS Group which stated (page 5) that, in the U.S., "the entire cost burden of providing IP relay and video relay services has fallen on the inter-exchange carriers, because it is not possible to determine whether calls that originate on the Internet are local or long distance calls. When (IP relay and video relay services) are introduced in Canada , a similar problem could arise with IP relay and video relay service to the extent that a carrier will not know whose customer is using the services. User registration could be one way to determine where an IP or video call originates."

Indicate whether you have any concerns with respect to requiring users to register in order to use IP relay services or VRS.   If such concerns exist, describe how they could be alleviated.

QUESTION 2: In Bell Canada(CRTC)10Jun08-100 Attachment 2, Bell Canada submitted a report by the PELORUS Group which stated (page 14) that in the U.S. , Speech recognition technology is being used to enhance traditional TTY, which significantly increasing the flow of conversations by partially automating the Call Assistant (CA) function.

Indicate what importance and value you put on increasing the flow of conversations via TTYs. Indicate whether you view the automation of the CA function as described above as an effective means to this end.

 

G) QUESTIONS TO BELL CANADA

QUESTION 1:   Many TSPs indicated that they receive few complaints related to accessibility. However, disability advocacy groups have indicated that there is significant concern among persons with disabilities about the current and future accessibility of telecommunications services.

a)   In Bell Canada (CRTC)10Jun08-100, Bell Canada submitted that its "customers are invited to submit concerns and suggestions regarding products and services to improve accessibility to the Company's services via the Special Needs Centre on Bell.ca. Comments reviewed are forwarded to the Office of the Accessibility Manager for review."

Describe any measures Bell Canada has taken to promote awareness of the " Special Needs Center on Bell.ca" to its customers (e.g. bill inserts). Describe any measures Bell Canada has taken to provide an alternative method of receiving such concerns (e.g. from customers who may be unable to access the Company's website).

b) In Bell Canada(CRTC)10Jun08-100, Bell Canada indicated that it has long-standing relationships with groups representing persons with hearing disabilities. Bell Canada also indicated that it is working on a project to improve services for persons with speech-related disabilities.   Indicate the frequency of Bell Canada 's consultations with groups representing persons with disabilities related to a) sight, b) mobility/agility, and c) cognition.

QUESTION 2:   In Bell   Canada (CRTC)10Jun08-100, Bell Canada submitted that "For TTY users to be able to use 9-1-1 , the Public Service Answering Point (PSAP) must be able to identify that the incoming call is from a TTY device. .the Company is aware that some PSAPs have difficulty identifying when a call is coming from a TTY device."

a) Indicate why some PSAPs do (or might) have difficulty identifying when a call is coming from a TTY when others do not.

b) Describe the solutions or technologies that have enabled those PSAPs that do recognize TTYs calls to do so.

c) Indicate how (i.e. when, by whom, e.g. a complaint on behalf of a person using a TTY) you were made aware that some PSAPs have difficulty identifying when a call is coming from a TTY.

QUESTION 3:   In Bell   Canada (CRTC)10Jun08-100, Bell Canada indicated that Bell Mobility received complaints related to "billing issues reported by account representatives acting on behalf of customers with cognitive disabilities that arose because the customers did not understand the terms of their contracts."

Describe the measures your Company has taken to improve the accessibility of its contracts (and/or other documents) to customers with cognitive disabilities (e.g. whether you make available, upon request, plain language versions of such documents).

 

H) QUESTIONS TO NEIL SQUIRE SOCIETY

QUESTION 1:   At paragraph 6 of its 24 July comments, the Neil Squire Society stated:

" Despite the social responsibility of industry, the desire to help persons with disabilities does not translate into corporate policy or business decisions. There is a role for regulation and most of the major strides in disability rights and inclusion in the last decade have come about due to regulations. It is important to not over look the catalyst effect regulation has on industry to deliver on their social contract."

Provide example(s) of major strides in disability rights and inclusion in the last decade that have come about due to regulations, providing details on: circumstances; governing legislative or regulatory framework; implementation requirements, and outcome and benefit in quantifiable terms.

QUESTION 2:   At paragraph 14 of its 24 July comments, the Neil Squire Society also stated in regard to emergency services:

"In fact, may [sic] emergency services protocols are now integrating these types of devices and services into the core of their procedures.   However, if these devices and services are not accessible (as per paragraph 9) then persons with disabilities will be excluded from this extremely valuable form of receiving assistance in an emergency situation -- often the very individuals who are at most risk.   So once again, it becomes imperative that that the CRTC use its authority to ensure that persons with disabilities have proper access to these devices and services."

Explain, with examples:

a)   The manner in which emergency services protocols are being integrated with certain types of devices into the core of their procedures.

b) The impact of this integration to accessibility of emergency services protocols to persons with disabilities, particularly those who are at most risk, identifying any barriers that such integration may cause, including those that pertain to necessary compatibilities, upgrades or support.

 

I) QUESTION TO ARCH DISABILITY LAW CENTRE

QUESTION 1:   At paragraph 14 of its 25 July revised comments, ARCH stated in regard to foreign jurisdictions:

"Regulatory measures should be established taking into account examples of the same issue from telecommunications regulators in other jurisdictions, such as the United States and Australia , as well as international standards and obligations."

a)   Provide relevant examples from other jurisdictions of regulatory measures taken in regard to accessibility for persons with disabilities to new telecommunications technology and products.   For each regulatory measure taken, specify the relevant legislative or regulatory framework of the cited jurisdiction.

b)  For each example, provide the outcomes that these regulatory measures have produced in quantifiable benefits to persons with disabilities, as well any cost data that is available.   Specify the longevity of these benefits.

c)  Specify the international standards and obligations referenced by ARCH.

 

J) QUESTION TO THE COUNCIL OF CANADIANS WITH DISABILITIES

QUESTION 1:   At section 20.2 of its 24 July comments, the Council of Canadians with Disabilities (CCD) submitted that "the CRTC has a responsibility to ensure that persons with disabilities have equal access to emergency services. The CCD recommended that the CRTC use its authority to ensure that 911 services are accessible to the users of TTYs, Voice Carry Over services, phone text messaging, and IP services."

a) Describe how people with disabilities do not currently have equal access to emergency services when using those services.

QUESTION 2:   At section 2.1.2 of its 24 July comments, the CCD submitted that "All pay phone installations must follow universal design principles so that the widest possible range of people with disabilities have access to them."

Describe any modifications that you are aware of that would make pay telephones more accessible to a wider range of persons with disabilities. When listing possible modifications, indicate whether they have been implemented in other jurisdictions and the associated priority (ranking) for such modifications.

 

QUESTION TO THE VRS CONSULTATIVE COMMITTEE OF BC

QUESTION 1:   At paragraphs 65-68 of its 10 July comments, the VRS Consultative Committee of BC submitted that "Earlier this year an official notice was put out to BC citizens that the availability of TTYs at emergency call centres (911) was uncertain."   The VRS Consultative Committee of BC proposed a) that the Commission look to other jurisdictions that are now using E9-1-1, VRS, and IP relay services and b) texting through phones for emergencies.

a) Indicate who distributed the notice that the availability of TTYs at emergency call centres (911) was uncertain.  

b) Indicate which specific jurisdictions you recommend that the Commission use as a model with respect to the provision of the above-noted services as they relate to emergency services. Further, indicate which initiatives from those other jurisdictions your Company thinks warrant further investigation by the CRTC and why.

c) List those jurisdictions where persons who are Deaf, Deafened or hard of hearing are able to contact emergency services (i.e. 9-1-1) via text messaging.

 

 

Date Modified: 2008-08-08