Telecom - Procedural Letter addressed to the Distribution list

Ottawa, 5 July 2022

Our reference: 1011-NOC2021-0102

Distribution List

Re:  Telecom Notice of Consultation 2021-102 - Review of Video Relay Service (VRS) - Procedural Request to extend Deadline for Reply Comments and Other Matters
Dear Terri Nolt and Megan McHugh,

This letter is in response to the procedural requests filed by the Canadian Deaf-Blind Collective (CDBC.VRS) made up by the Canadian National Society of the Deaf-Blind (CNSDB) and the Deaf-Blind Planning Committee (DBPC) on 19 May 2022 and 8 June 2022. This letter will address the following matters:

  1. Extension of deadline for reply comments
  2. Correction of e-mail contact information for CDBC.VRS
  3. Submission of addendum to intervention
  4. Joint reply – CDBC.VRS and Deaf Wireless Canada Consultative Committee
  5. Scheduling conflicts raised by the CDBC.VRS
  6. CRTC online file organization system


a. Extension of deadline for reply comments

The CDBC.VRS requested that parties to the proceeding submit all documents in MS Word format to ensure they are accessible to participants who are Deaf-Blind. This request was made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure.

As there was a two-week delay in receiving documents in the requested format, the CDBC.VRS requested that the deadline for reply comments be extended from 11 July 2022 to 29 July 2022.

Given the additional time required for the Canadian Administrator of VRS (CAV) to file responses to CRTC Requests for Information and interventions, and other participating parties to file their interventions in an alternate format, the Commission approves the request to extend the deadline for reply comments to 29 July 2022. This extension will apply to all parties in this proceeding.

b. Correction of e-mail contact information for CDBC.VRS

The CDBC.VRS requested to have the name and email address of the Chair of the DBPC removed from this and future proceedings in the interest of privacy.

The Commission’s proceedings are public by default and it does not accept anonymous submissions. While personal information submitted to the Commission is not indexed on search engines, intervenors agree to names and contact information being published on the Commission’s public proceedings web page when they provide this information in their interventions.  

In this case, though, the personal email address of the DBPC Chair is not part of the Commission’s official distribution list for this proceeding. Accordingly, parties should not be using it to correspond with DBPC or CDBC.VRS. CDBC.VRS has already reminded parties of its correct contact information in a procedural request dated 16 August 2021. It appears that other parties have, nonetheless, continued to use the personal email address.

Accordingly, while it would not be appropriate to remove the personal information from the record of the proceeding, the Commission takes this opportunity to remind parties of the correct contact information for the CDBC.VRS. Parties wishing to correspond with, or serve documents on, CDBC.VRS should only use the following addresses:

DBPC Chair:              ,
CNSDB President:     

While CDBC.VRS asked that its request also be granted in future proceedings, procedural requests only apply to the proceeding in which they are filed.

c. Submission of addendum to initial comments

In its intervention filed on 16 May 2022, the CDBC.VRS stated that its writing team experienced technical difficulties with the report it submitted as part of its intervention. As such, the CDBC.VRS decided to exclude the raw data documents from the report to reduce the number of pages.

The CDBC.VRS stated that the appendices with the raw data would be fixed and requested permission to submit an addendum before the close of the reply period.

Given the information is summarized in its intervention, the Commission is of the view that the later submission date of the raw data will not constitute a breach in procedural fairness. The Commission therefore approves the submission of the addendum prior to 29 July 2022.

d. Joint reply – CDBC.VRS and Deaf Wireless Canada Consultative Committee

In its request filed on 19 May, 2022, the CDBC.VRS stated that after experiencing confusion with document navigation, it discussed the matter with the Deaf Wireless Canada Consultative Committee (DWCC). Those discussions led to an agreement between the CDBC.VRS and the DWCC to pool their resources to work together and file a joint reply.

The Commission acknowledges that the CDBC.VRS and the DWCC will file a joint reply comment for this proceeding.

e. Scheduling conflicts raised by the CDBC.VRS

The CDBC.VRS expressed its wish to appear at the virtual discussion sessions to be held in the fall as part of this proceeding. It expressed concern, however, about a possible scheduling conflict for its members. Many of its members will be unavailable from 26 August to 2 September 2022. Additionally, the CDBC.VRS pointed out that Deaf-Blind participants will require three to four weeks’ notice to arrange for interpreters and intervenors to assist them during the sessions.

The Commission confirms that the virtual discussion sessions will take place after the dates referenced by the CDBC.VRS. More information on these sessions will be sent to those who have indicated their interest to participate, in the coming months. The Commission acknowledges the CDBC.VRS’ request to have at least three to four weeks’ notice prior to the sessions.


f. CRTC online file organization system


The CDBC.VRS stated that the online location where the CRTC houses all of the proceeding’s documents is difficult to navigate for Deaf-Blind persons.

At this time, organizing ZIP files along the lines suggested by CDBC.VRS is not technically feasible with the system used by the Commission. However, the feedback provided will be taken into consideration as the Commission begins work to modernize the system.

Until a more permanent solution can be found, the Commission can manually provide documents, organized in ZIP files, upon request.

Yours sincerely,

Original signed by


Claude Doucet
Secretary General


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