Telecom Commission Letter Addressed to Julia Dumanian (Canadian Hearing Society)
Ottawa, 7 June 2017
Our reference: 1011-NOC2017-0033
President and CEO
Canadian Hearing Society
271 Spadina Road
Toronto, Ontario M5R 2V3
Subject: Telecom Notice of Consultation CRTC 2017-33, Review of the regulatory framework for text-based message relay services
Dear Ms. Dumanian:
On 2 February 2017, the Commission issued Notice of Consultation (NoC) 2017-33 to review the regulatory framework for text-based message relay services (MRS review), which are text-to-voice services that enable people with a hearing or speech disability to make and receive telephone calls.
In order to ensure the Commission has a complete record in the MRS review, Commission staff is issuing letters to accessibility groups that expressed views regarding MRS in past proceedings, such as the Basic Telecommunications Services (BTS)Footnote1 and next-generation 9-1-1 (NG911)Footnote2 proceedings, in order to ask those groups whether they still hold their views.
Commission staff notes that the Canadian Hearing Society (CHS) is not a party to the MRS review, as CHS did not file an intervention by the Commission’s deadline of 3 April 2017 set out in NoC 2017-33. Nevertheless, given that CHS has expressed views regarding MRS in past proceedings, Commission staff is issuing the present request for information (RFI) letter to confirm whether CHS continues to believe that:
- “there is a lack of commitment to maintain quality standards of services in a technologically ever-changing environment.” CHS specifically recommended that telecommunications service providers (TSPs) be required to “maintain compatible and accessible levels” of relay services and that a CRTC Accessibility Advisory Committee be established to “monitor quality control, usage and innovations”Footnote3 ;
- “Culturally Deaf, oral deaf, deafened and hard of hearing TTY and Voice Carry Over (VCO) users miss calls from people who do not specifically call a TTY. Opportunities are lost and access eludes them.” CHS specifically recommended that “when callers reach a TTY or VCO number, the call be automatically transferred to a relay service who will relay the call using a TTY”Footnote3 ;
- “IP relay is only offered to residential landline accounts.” CHS specifically recommended that the CRTC “require TSPs to develop either a native application in mobile devices with iOS, Android and BlackBerry operating systems or to have a mobile-friendly html site that is easy to navigate and use the service”Footnote3 ;
- “many voice (spoken-language)-based services that require callers to identify themselves, and provide information for security purposes, do not accept relay service operators to relay the information from a deaf customer or customer with hearing loss, thus severing access to the service.” CHS specifically recommended relay service providers be “the legitimate voice representatives for deaf customers or people with hearing loss who rely on such means to access services”Footnote3;
- “TTY technology is not compatible or reliable with Internet technology. As communication infrastructure technology changes they become redundant”Footnote4; and
- “TTY sales in Ontario are definitely on the decline”Footnote4.
Commission staff is requesting that you reply to this letter by 13 June 2017 by confirming, as noted above, whether CHS continues to hold the views it had expressed in the BTS and NG911 proceedings. Your reply to this letter will permit parties to comment on CHS’s views by 23 June 2017, which is the deadline set out in NoC 2017-33-1 for parties to comment on responses to RFIs filed by other partiesFootnote5.
We value CHS’s contributions to the Commission’s public consultations and look forward to receiving CHS’s comments during the present MRS review.
If you have any questions with regards to this letter, please contact Bradley Gaudet at email@example.com.
originally signed by
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy
c.c.: Gary Malkowski, VP Stakeholder & Employer Relations, CHS, firstname.lastname@example.org
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