Telecom - Commission Letter addressed to Sue Decker (Canadian Administrator of VRS (CAV))

Ottawa, 11 March 2021

Our reference: 1011-NOC2021-0102


Sue Decker
CEO and Executive Director
Canadian Administrator of VRS (CAV)
Ottawa, Ontario

RE: Review of video relay service (VRS)

Dear Ms. Decker,

Pursuant to paragraph 7 of Review of video relay service (VRS), Telecom Notice of Consultation CRTC 2021-102, attached is the request for information addressed to the Canadian Administrator of VRS (CAV). The CAV is to file its responses with the Commission by 26 April 2021.

Procedural information 

This letter and all subsequent correspondence form part of a public record.  As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential.  A person claiming confidentiality with respect to information submitted must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

If you have any questions regarding this letter, please contact Jennifer Porteous at 819-997-4819 or by email at

Yours sincerely,

Original signed by Nanao Kachi

Nanao Kachi
Director, Social and Consumer Policy
Consumer, Research and Communications
Canadian Radio-television and Telecommunications Commission

c.c.:   Jennifer Porteous -


Governance structure and mandate

  1. File the most recent English and French versions of the CAV’s constituting documents, including (i) the CAV’s letters patent; (ii) bylaws; (iii) mandate; (iv) stakeholder, member, or Director agreements; and (v) any other relevant corporate documents.
  2. Describe the composition of the Board of Directors and the Director selection process.
  3. Provide the amount each Board of Director receives in compensation and the method used to set this amount.
  4. Describe the role of the CAV’s registered stakeholders.
  5. In the process leading to Telecom Decision 2020-394 (the VRS 2021 budget decision), Bell Canada raised concerns with certain aspects of the CAV’s budget request for 2021, specifically the CAV’s long-term deferred contributions.  The CAV noted that its Board of Directors had begun a review to determine the level at which the long-term deferred contributions should be maintained.  As set out in the VRS 2021 budget decision, the CAV is required to file a copy of that review, as well as a description of any actions taken in response, on the record of this proceeding.

Architecture, operations, and technical requirements

  1. Provide an overview of the technical architecture and operations of VRS, including the video platform provider and the video interpreter providers, including
    1. how the system has been engineered for redundancy to provide seamless services and minimize outages;
    2. how the service is monitored to ensure it is functioning optimally;
    3. whether there are planned service outages and, if so , what the reason is and how are users alerted;
    4. the process for transferring calls between video relay interpreters (VIs) including how users are warned in advance, why this is sometimes necessary, and what approaches, if any, have been used to minimize such transfers; and
    5. any other mechanisms established to mitigate operational issues.
  2. How has the COVID-19 pandemic affected operations and what changes, if any, have been made to the service’s operational processes and delivery?
  3. Describe the screening and training process for VIs as well as any guidelines that VIs must conform to while providing VRS.
  4. What efforts have been made to ensure gender and ethnic diversity of VIs?
  5. Does the CAV employ any Deaf interpreters?
  6. To what extent does VRS rely on American interpreters? Has this changed over time? Is it now feasible to employ only Canadian interpreters?
  7. Has the CAV considered interoperability with other jurisdictions’ VRS to facilitate international point-to-point calls? If so, what did the CAV conclude or implement as a result?
  8. Demonstrate how the CAV meets the minimum requirements for the VRS administrator, which are set out in Regulatory Policy CRTC 2014-187.


  1. Explain how VRS complies with the minimum service requirements set out in the Regulatory Policy CRTC 2014-187.
    1. Please provide specific details about how 9-1-1 calls are handled and any limitations associated with 9-1-1 calls, including the provision of the caller’s address, and identify what, if anything, has been put into place to mitigate these limitations.
    2. Describe how a VI is instructed to handle a 9-1-1 call, including how the VI facilitates communications between the first responders and the caller and what are the guidelines for establishing when the VI terminates the call.
  2. What enhancements has the CAV made to VRS beyond the minimum requirements, and what are its plans for further enhancements?
    1. How has the CAV incorporated feedback from its users into its plans for enhancing VRS?
  3. Describe the features and ancillary services available to VRS users, including call alerts, long distance calling, conference calling, sign-language “voicemail,” voice carry over, and hearing carry over. In the description indicate which services are available on which platforms.
    1. Are there any costs to users or additional requirements for these features and services? If so, elaborate.
    2. What are the limitations of these features and services, if any? If so, elaborate.
  4. Describe the technical requirements for users of the service, including platforms supported and bandwidth requirements.
  5. Describe any technical limitations of VRS and the reasons for them. What would need to put into place to allow VRS users to use these numbers. For example, explain why users cannot make VRS calls to numbers like 2-1-1, 3-1-1, 5-1-1, 6-1-1, and 8-1-1.  Would you be able to provide any advice on how a proposed 988 suicide hotline number could be designed to make it accessible to VRS users?


  1. What are the CAV’s VRS usage policies related to maximum call duration, account suspension, conference calls, number of calls that can be made during a session, and any others?
  2. Provide English and French copies of the VRS user agreement, privacy and confidentiality policy, fair usage policy, and any other user policy document developed by the CAV.
  3. Are these policies available to users in ASL and LSQ?

User engagement, feedback, and support

  1. Explain how Canadians whose first language is a sign language were involved in the development of VRS and how the CAV continues to engage with its users as it improves and evolves the service.
  2. Describe the CAV’s feedback, inquiry, and complaint-handling processes for spoken and signed-language users, including the various channels available to users and the approach taken to resolve complaints or respond to feedback.
  3. Provide the number of each type of customer service inquiry the CAV has received, including complaints, for every year that VRS has been in operation.
  4. Describe how the CAV measures user satisfaction and the results of these measurements.
  5. Does the CAV publish its performance metrics on a regular basis and, if so, which metrics does it publish and how often? Where is this information published (e.g., annual report, website, or newsletter)?
  6. Describe how the CAV has used ASL and LSQ videos to communicate with and supply training materials and guides to its users. Provide a list of all available materials.

Quality of service standards and metrics

  1. Describe any quality of service standards established by the CAV and provide metrics associated with these standards from the launch of the service to present, broken down monthly if possible.
  2. What are the CAV’s recommendations on appropriate minimum quality of service standards?
  3. Provide the following performance statistics from the launch of the service to present, broken down monthly if possible:
    1. Average wait times for an interpreter, broken down by ASL and LSQ
    2. Average call duration
    3. Number of ASL and LSQ calls, broken down by relay calls and point-to-point calls
    4. Number of subscribers
    5. Number of dropped calls, broken down by ASL and LSQ
    6. Number of abandoned calls, broken down by ASL and LSQ
    7. Number of calls not accepted by the person being called
    8. Number and duration of outages, including the number of unplanned outages and the cause of each
  4. For each of the unplanned outages, provide a description of what was put into place to lessen the frequency of future outages or prevent them where possible.

Education, outreach and public awareness

  1. Describe outreach that the CAV has undertaken to educate consumers who are Deaf or hard of hearing, or who have speech disabilities, about VRS.
  2. Describe how the CAV has used ASL and LSQ videos to promote VRS, and provide a list of those materials.
  3. Describe any efforts the CAV has made to increase awareness and acceptance of VRS calls among the general public and businesses, including banks, credit card companies, and other institutions.
  4. Provide a copy of the CAV’s current public awareness and outreach plan in English and French.


  1. The Sage Report, which is provided on the record of this proceeding, documented a number of issues and suggestions raised by a sample of VRS registered users, some of which have not been addressed by the questions above. Provide feedback on the appropriateness and feasibility of those recommendations for the following issues:
    1. A mechanism for users to provide feedback on their VI
    2. Allowing users to schedule calls at specific times
    3. Providing an option for users to skip the introduction that the VI provides to the hearing party
    4. Call recording
    5. Pasting in phone numbers
    6. Caller id
    7. Adjusting the app’s colour scheme
    8. Bilingual options
    9. The ability to select a specific VI
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