Telecom Commission Letter Addressed to Lui Greco (Canadian National Institute of the Blind (CNIB))
Ottawa, 22 July 2016
Our reference: 1011-NOC2016-0116
National Manager of Advocacy
Canadian National Institute of the Blind (CNIB)
Re: Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116 – Requests for information
Dear Mr. Greco,
Pursuant to the procedure set out in Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116, 29 March 2016, attached are requests for information addressed to the Canadian National Institute of the Blind (CNIB).
Responses to these requests for information are to be filed with the Commission by 23 August 2016.
Original signed by Kim Wardle for/
A/Director, Competition and Emergency Services Policy
c.c. Renée Doiron, CRTC, 819-997-2755, Renee.Doiron@crtc.gc.ca
James Ndirangu, CRTC, 819-997-3670, James.Ndirangu@crtc.gc.ca
- In paragraph 25 of its intervention, the CNIB submitted that “…subscribers who are deaf-blind or who have other communication disabilities should be able to attach a user profile to their mobile or landline number.” In your view, what information should be included in a user profile? How would this information be used to better serve these subscribers?
- Accessibility Groups generally argued that accessibility should be taken into account in the development of the new NG9-1-1 system, rather than retrofitted once the system has been deployed. Media Access Canada added that Canadians with disabilities are particularly challenged with accessing a system inherently designed for persons without disabilities. Describe your view of what an ideal inclusively-designed NG9-1-1 system would look like without being bound by existing architecture or services. Specifically,
- What aspects should be included in the system design?
- How would this system address the needs of Canadians with disabilities represented by your organization(s)? What issues would it address?
- How would this system resolve issues that are currently encountered with the existing system?
- What are the most effective ways of reaching Canadians with disabilities to ensure that they are aware of the system and how to use it?
- The outcome of the United States Federal Communications Commission (FCC) Notice of Proposed Rulemaking (NPRM) 16-53Footnote1 may impact the availability of wireless and wireline terminal equipment (smartphones, telephone sets, etc.) that support TTY relay service. Given the critical nature of 9-1-1 services, provide your view, including supporting rationale, as to whether there would be effects on Canadians with disabilities resulting from TTY relay service not being supported in an NG9-1-1 environment. Include in your answer
- your assessment of whether there are risks to your community, as well as the number of people who will be affected and how. If exact numbers are not known, provide estimates and an explanation as to how the numbers were estimated; and
- an estimated time frame for when TTYs will no longer be used.
- Provide your view on the best means of informing members of the public who will be directly affected should TTY relay service not be supported in an NG9-1-1 environment.
- Leveraging lessons learned during the recent rollout of Text with 9-1-1 for Canadians who are Deaf, hard of hearing, or have a communication disability, should the rollout of NG9-1-1 services be coordinated and rolled out at the regional, provincial, or individual PSAP level? Explain the benefits, challenges, and risk mitigation strategies associated with your proposal.
- Footnote 1
On 29 April 2016, the FCC issued NPRM 16-53 (https://www.fcc.gov/document/real-time-text-nprm), in which it proposed amendments to its rules “to facilitate a transition from outdated text telephone (TTY) technology to a reliable and interoperable means of providing real-time text communication for people who are deaf, hard of hearing, speech disabled, and deaf-blind over Internet Protocol (IP)-enabled networks and services.” Specifically, in Appendix C, paragraph 3, the FCC seeks comment on “…its proposal that service providers should be required to make their RTT services interoperable with TTY technology supported by circuit-switched networks, and when that requirement should sunset” [emphasis added]. In paragraph 65, the FCC seeks comment on “…what events or measures should trigger a sunset of the residual obligation for wireless networks to be backward compatible with TTY technology.” In paragraph 99, the FCC seeks comment on “…how should TTY support obligations be modified as wireline networks discontinue their circuit-switched services?”.
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