Telecom Notice of Consultation CRTC 2020-178-3

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References: 2020-178, 2020-178-1, 2020-178-2, 2020-178-4 and 2020-178-5

Ottawa, 23 March 2021

Public record: 1011-NOC2020-0178

Call for comments – Accessibility – Mobile wireless service plans that meet the needs of Canadians with various disabilities – Changes to procedure

Revised intervention and reply deadlines and changes to procedure

Revised deadline for the submission of interventions: 25 May 2021

Revised deadline for the submission of replies: 9 July 2021

  1. On 26 August 2020, the Commission suspended all deadlines for the proceeding initiated by Telecom Notice of Consultation 2020-178 until further notice. The Commission did so in response to a request from the Deaf Wireless Canada Consultative Committee (DWCC), the Canadian Association of the Deaf, and the Canadian National Society of the Deaf-Blind, Inc. (collectively, DWCC et al.) for an extension to the intervention deadline, and while it considered another request by DWCC et al. for a virtual public hearing.
  2. Specifically, by letter dated 14 July 2020, DWCC et al. requested that the proceeding be modified to include a virtual public hearing component, submitting that this would permit groups like DWCC et al. and the Deaf, deaf-blind, and hard-of-hearing individuals they represent an opportunity to present their comments in American Sign Language (ASL) or Langue des signes québecoise (LSQ). DWCC et al. also requested, among other things, additional time to present during this requested hearing and that sign language interpreters be present throughout its entirety.
  3. No other parties requested a virtual public hearing for the proceeding. However, the Deafness Advocacy Association Nova Scotia, Newfoundland and Labrador Association of the Deaf, and Ontario Association of the Deaf, (collectively, the DHH [Deaf and hard-of-hearing] Coalition) submitted that, should the request to hold a virtual public hearing be granted, they would like an hour to present, in line with what DWCC et al. requested in their 14 July 2020 letter.
  4. The Commission notes that DWCC et al. emphasized the importance of their members having the opportunity to present their comments on the issues in this proceeding in ASL or LSQ. However, the Commission also recognizes that there are uncertainties related to public health guidelines during the ongoing COVID-19 pandemic and how the Commission would manage a virtual public hearing incorporating the appropriate accessibility considerations under these circumstances. While a virtual public hearing could provide participants with a forum in which they could present their positions in ASL or LSQ, there are other ways in which participants can express their views to the Commission in ASL or LSQ. The Commission therefore denies DWCC et al.’s request for a virtual public hearing.
  5. However, in order to address DWCC et al.’s main concern that Canadians who are Deaf, deaf-blind, or hard of hearing have an opportunity to present their comments on the issues under consideration in ASL or LSQ, the Commission is modifying its general procedures for the purposes of this proceeding. Specifically, in light of the circumstances, the Commission is inviting Canadians to submit their interventions and replies in ASL or LSQ, in video format, if they so choose. Links to these videos will be posted on the public record of this proceeding and a transcript of each video will be created by the Commission and added to the public record as an intervention or reply.
  6. In order to provide sufficient time for individuals and groups to create videos in ASL or LSQ and to ensure that all parties have the opportunity to review the transcripts of these videos, the Commission is also modifying its general procedures for this proceeding by establishing longer intervention and reply periods.

Revised deadlines

  1. The revised deadline for all interventions in this proceeding is 25 May 2021. The revised deadline for all replies is 9 July 2021.
  2. Submissions must be filed by sending them to the Secretary General of the Commission using only one of the following means:

by completing the
[Intervention form]
by mail to
CRTC, Ottawa, Ontario K1A 0N2
by fax to
by ASL or LSQ video using the
[Intervention form]

Revised procedure for video submissions

  1. The Commission will accept video interventions and replies in ASL and LSQ for this proceeding. The deadline for submitting video interventions is 25 May 2021. Interested persons must provide a working link to a publicly viewable version of their video in the comments box in the “Submit an intervention” section of the Intervention form. All other submission procedures are the same as for written interventions, which are set out in the previous section of this notice.
  2. The deadline for submitting video replies is 9 July 2021. If parties choose to submit a video reply in ASL or LSQ, they are to follow the same procedure as in paragraph 9 above. Replies must respond only to interventions and answers to Commission requests for information previously submitted by other parties.
  3. The Commission will post English transcripts of ASL videos and French transcripts of LSQ videos on its website as interventions or replies on the public record of this proceeding. Links to videos will be made public when the transcripts become available. Interveners may choose to submit written transcripts with their videos to facilitate the process.
  4. For videos longer than 15 minutes, a brief summary should be provided at the beginning of the video.
  5. The information that parties provide to the Commission as part of this public process is entered into an unsearchable database dedicated to this specific public process. In the case of information submitted via ASL or LSQ videos, the transcripts of these videos will also be entered into the unsearchable database. This database is accessible only from the web page of this particular public process. As a result, a general search of the Commission’s website with the help of either its search engine or a third-party search engine will not provide access to the information that was provided as part of this public process. However, because individuals who submit an ASL or LSQ video intervention or reply must submit a working link to a publicly viewable version of their video to the Commission, depending on where the video was uploaded, any intervention or reply submitted via ASL or LSQ video may be searchable by a third-party search engine.

Secretary General

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