MAC CRTC Submissions

INTRODUCTION OF THE ACCESS 2020 GROUP OF ACCESSIBILITY ORGANIZATION'S PANEL

BEVERLEY MILLIGAN

THANK YOU, MADAME SECRETARY AND GOOD MORNING. FOR THE RECORD, MY NAME IS BEVERLEY MILLIGAN OF MEDIA ACCESS CANADA. MAC WAS CREATED BY AND ITS BOARD OF DIRECTORS CONSISTS PRIMARILY OF NATIONAL DISABILITY ORGANIZATIONS ACROSS CANADA THAT BENEFIT FROM ACCESSIBLE MEDIA. THEIR GOAL IS TO ACHIEVE FULL ACCESSIBILITY IN CANADA'S COMMUNICATIONS SYSTEMS BY 2020 THROUGH PARTICIPATION IN HEARINGS SUCH AS THIS AND SPEAKING AS ONE VOICE ON ISSUES CONCERNING ACCESSIBILITY ON BEHALF OF CANADIANS WITH DISABILITIES. THROUGH THIS PROCESS OF WORKING TOGETHER, WE ARE ABLE TO DEVELOP THE NECESSARY EXPERTISE TO BETTER COMMUNICATE KEY ISSUES TO ALL STAKEHOLDERS. WE EDUCATE OUR MEMBERS AND OTHER STAKEHOLDERS WITH THE GOAL OF COLLABORATION AND PARTICIPATION IN ENSURING ACCESS TO MEDIA. WE CONTINUE TO GROW AND EXPAND TO INCLUDE ALL DISABILITY ORGANIZATIONS REPRESENTING AND SERVING THE INTERESTS OF CANADIANS WITH DISABILITIES; IT IS MY PLEASURE TO INTRODUCE SOME OF OUR MEMBERS TODAY.

TO MY IMMEDIATE RIGHT IS DR. GARY BIRCH, OUR TELECOMMUNICATIONS SUBJECT MATTER EXPERT AND CEO OF THE NEIL SQUIRE SOCIETY. TO HIS RIGHT IS LAURIE ALPHONSE, REGIONAL MANAGER FOR THE DISABLED WOMEN'S NETWORK.

TO MY IMMEDIATE LEFT IS ROBERT CORBEIL, EXECUTIVE DIRECTOR OF THE CANADIAN HARD OF HEARING ASSOCIATION; TO HIS LEFT GARY SAXON OF THE CANADIAN COUNCIL OF THE BLIND.

IN THE SECOND ROW, FROM YOUR LEFT TO RIGHT IS LUI GRECO OF THE ALLIANCE FOR EQUALITY OF BLIND CANADIANS; CHRISTINE ROBBINS, REPRESENTING CNIB, MARY FRANCES LAUGHTON, SENIOR RESEARCHER FOR MAC AND MICHEL DAVID, REGIONAL DIRECTOR FOR THE CANADIAN HEARING SOCIETY.

BACKGROUND

1. COMMISSIONERS, COMMISSION STAFF AND MEMBERS OF THE AUDIENCE - GOOD MORNING AND THANK YOU FOR THE OPPORTUNITY TO APPEAR BEFORE YOU TODAY TO SPEAK AS ONE ON BEHALF OF THE MILLIONS OF CANADIANS WITH DISABILITIES.
2. OUR OBJECTIVE IS TO DISCUSS THE RECOMMENDATIONS IN OUR WRITTEN SUBMISSION AND MORE SPECIFICALLY MAKE THE COMMISSION AWARE OF THE ISSUES THAT ARE OF TOP PRIORITY TO THE DISABILITY COMMUNITY AS REGARDS THE CODE OF CONDUCT BEING DISCUSSED IN THESE HEARINGS. WHILE PEOPLE WITH DISABILITIES HAVE ALL OF THE SAME CONCERNS AS OTHER CONSUMERS AND ARE SIMILARLY EFFECTED IN DETRIMENTAL WAYS BY SPECIFIC POLICIES PUT IN PLACE BY THE TELECOMMUNICATIONS INDUSTRY AND THE INDIVIDUAL WIRELESS SERVICE PROVIDER IN PARTICULAR, THERE ARE SPECIFIC ISSUES AND CONCERNS UNIQUE TO THE DISABILITY COMMUNITY.
3. HISTORICALLY THE CONCERNS OF THE DISABILITY COMMUNITY HAVE BEEN DEALT WITH IN A SEPARATE PROCESS BY THE CRTC. THE CRTC HAS PROVIDED SPECIFIC ACCOMMODATIONS TO SUPPORT THE NEEDS OF PEOPLE WITH DISABILITIES. HOWEVER, WE URGE THE COMMISSION TO FORMALLY RECOGNIZE THESE ACCOMMODATIONS AND CREATE A FRAMEWORK FOR ADDITIONAL ACCOMMODATIONS THROUGH THE CREATION OF A SEPARATE SECTION WITHIN THE OVERALL WIRELESS CODE OF CONDUCT SPECIFICALLY ADDRESSING THE UNIQUE NEEDS OF CANADIANS WITH DISABILITIES.
4. IN ADDITION, WE ASK THIS NOT BE DEFERRED TO A SEPARATE DISABILITY HEARING AT SOME TIME IN FUTURE, BUT THAT IT BE ADDRESSED AT ONCE TO ENSURE THE SAME OR "EQUIVALENT" RIGHTS AS FOR ALL CANADIANS.

GARY BIRCH

1. WE BELIEVE THIS HEARING IS AN OPPORTUNITY, THROUGH THE CREATION OF A MANDATORY WIRELESS CODE OF CONDUCT, TO CREATE A MOBILE SYSTEM THAT IS FAIR TO ALL STAKEHOLDERS INCLUDING CANADIANS WITH DISABILITIES.
2. IN THE FILING, MAC POINTED TO PRECEDENT IN OTHER JURISDICTIONS AND INTRODUCED THE CONCEPT OF A SPECIFIC SECTION IN A CODE OF CONDUCT DEALING WITH ISSUES UNIQUE TO CANADIANS WITH DISABILITIES. WE RECOGNIZE THAT WITH THE ADVENT OF SMARTPHONES, ALL CANADIANS ARE USING THE PHONE FOR MORE THAN JUST TALKING TO EACH OTHER. FOR CANADIANS WITH DISABILITIES, THE ABILITY TO COMMUNICATE WIRELESSLY HAS FUNDAMENTALLY CHANGED THEIR ABILITY TO ACCESS CANADA'S TELECOMMUNICATIONS SYSTEMS.
3. WE ALSO RECOGNIZE THAT THE PACE AT WHICH TECHNOLOGY CHANGES HAS CREATED A TECHNOLOGY GAP THAT HAS LEFT PEOPLE WITH DISABILITIES BEHIND. ONE OF TH FUNDAMENTAL CAUSES OF THIS GAP IS THE SLOW PACE AT WHICH REGULATIONS AND POLICIES CHANGE. IN THE 2008 ACCESSIBILITY HEARINGS THE CRTC ACKNOWLEDGED THAT THE OBLIGATION FOR WIRELESS SERVICE PROVIDERS TO PROVIDE ACCESSIBLE PRODUCTS AND SERVICES EXTENDED TO NEW SERVICES SUCH AT TEXT MESSAGING, EMAIL AND INTERNET BROWSING. IN THE PAST WIRELESS SERVICE PROVIDERS CONTENDED THAT THEIR OBLIGATION ONLY EXTENDED TO THE OLDER DEFINITION OF SERVICES, ESSENTIALLY VOICE BASED TELEPHONE SERVICES. OTHER JURISDICTIONS SUCH AS THE UNITED STATES HAVE ALSO RECENTLY EXPANDED THE DEFINITION OF SERVICES THROUGH THEIR OWN LEGISLATION. THE NEED FOR THIS EXPANSION IS A RESULT OF THE UNWILLINGNESS OF THE WIRELESS INDUSTRY TO RE-DEFINE THEIR OBLIGATIONS VOLUNTARILY IN THE AREA OF ACCESSIBILITY.
4. MAC STRONGLY FEELS THAT ANY CODE OF CONDUCT SHOULD FORMALLY RECOGNIZE THE OBLIGATIONS THAT THE CRTC HAS IMPOSED ON THE WIRELESS SERVICE PROVIDERS IN THE AREA OF ACCESSIBILITY. FURTHER MORE, WE WOULD RECOMMEND THE CODE OF CONDUCT SHOULD BE FLEXIBLE ENOUGH TO ACCOMMODATE THE CHANGING NATURE OF THE PRODUCTS AND SERVICES OFFERED BY THE WIRELESS SERVICE PROVIDERS, SO THAT FORMAL HEARINGS ARE NOT REQUIRED EVERY TIME A NEW SERVICE NOT EXPLICITLY REFERRED TO IN THE CODE OF CONDUCT IS ADDED.
5. THE WIRELESS INDUSTRY HAS SUGGESTED THAT THE CODE OF CONDUCT UNDER CONSIDERATION MAY FUNCTION TO STREAMLINE PROCESSES SO THAT THEY DON'T HAVE TO DEAL WITH VARYING CONSUMER RIGHTS IN EACH REGION OF THE COUNTRY. MAC FEELS THAT IT IS IMPORTANT TO STREAMLINE THE PROCESS IN REGARDS TO DEFINING THE OBLIGATION OF WIRELESS SERVICE PROVIDER TO PROVIDE ACCESSIBLE PRODUCTS AND SERVICES TO PEOPLE WITH DISABILITIES IN LIGHT OF QUICKLY CHANGING TECHNOLOGY.

ROBERT CORBEIL

1. I WOULD LIKE TO DISCUSS INCLUDING A REQUIREMENT TO PROVIDE A LA CARTE SERVICES TO CANADIANS WITH DISABILITIES. AND IT REALLY BOILS DOWN TO ONE QUESTION, WHICH IS: SHOULD CANADIANS WITH DISABILITIES HAVE TO PAY FOR SERVICES, WHICH THEY SIMPLY CANNOT USE?
2. TO STATE THE OBVIOUS, A DEAF PERSON CANNOT USE AUDIO CAPABILITIES OF A "TELEPHONE"; A HARD OF HEARING PERSON WHO CAN USE THE AUDIO WILL OFTEN CHOOSE NOT TO AS ONE COULD LIKEN IT TO SOMEONE WHO NEEDS READING GLASSES TRYING TO READ WITHOUT THEM. NOT FUN. A BLIND PERSON CANNOT EASILY, OR SIMPLY MAY NOT WANT TO USE TEXTING OR E-MAIL ON THEIR PHONE. VERY LITTLE VIDEO OR AUDIO IS CAPTIONED OR DESCRIBED ON WEBSITES, SO DATA PLANS, RELATIVE TO ACCESS ARE MORE EXPENSIVE. MY FEW EXAMPLES DON'T CONSIDER THE LARGER SPECTRUM OF DISABILITY, OR DISCUSS CANADIANS WITH CROSS DISABILITY ISSUES.
3. THESE ISSUES HAVE BEEN REPORTED OVER AND OVER AGAIN TO WIRELESS SERVICE PROVIDERS, BUT TO DATE, OUR OWN RESEARCH OF THE MARKETING MATERIAL OF THE WIRELESS SERVICE PROVIDERS AND INQUIRIES AT THROUGH THE CUSTOMER SUPPORT CHANNELS OF THE WIRELESS SERVICE PROVIDERS INDICATE THERE IS NO WIRELESS MOBILE PLAN IN EXISTENCE THAT ADDRESSES THE NEED FOR FLEXIBILITY REQUIRED BY CANADIANS WITH DISABILITIES... NONE... NOT ONE.
4. THE WSPS HAVE HAD THE KNOWLEDGE AND THE OPPORTUNITY TO VOLUNTARILY ADDRESS, IN THEIR SERVICE PLAN CONTRACTS ACCOMMODATIONS FOR CANADIANS WITH DISABILITIES AND THEY HAVE FAILED TO DO SO. FOR THIS REASON WE ASK THAT THE COMMISSION ENSURE A MANDATORY REQUIREMENT FOR A LA CARTE SERVICES FOR CANADIANS WITH DISABILITIES.

LAURIE ALPHONSE

1. IN THE SUMMER OF 2009, I DECIDED TO UPGRADE TO A SMARTPHONE. THE SALES CLERK WAS VERY NICE WHEN I EXPLAINED TO HIM THAT I NEEDED SOMETHING DURABLE BECAUSE WITH MY DISABILITY COMES COORDINATION AND DEXTERITY ISSUES AND I WAS CERTAIN WHATEVER PHONE I BOUGHT WOULD BE DROPPED SEVERAL TIMES OVER ITS LIFETIME. I WAS WILLING TO GET THE NEWEST PHONE BECAUSE THEN I WOULD HAVE MORE TIME BEFORE THE TECHNOLOGY WENT OUT OF DATE.
2. I PAID THE FULL COST OF THE PHONE A PLAN INCLUDING THE OPTION TO PAY SEVEN DOLLARS MONTHLY FOR SMART PHONE REPLACEMENT COST SHOULD MY PHONE EVER NEED REPLACING. IT TOOK ALL OF A WEEK BEFORE I WAS BACK AT THE STORE NEEDING TO AVAIL MYSELF OF THE WARRANTY. IT WAS THEN AND ONLY THEN I LEARNED THE REPLACEMENT COST WAS IN FACT $150. I ASKED, IF I WAITED A COUPLE MONTHS AND PAID MORE INSTALLMENTS INTO THE WARRANTY WHETHER THAT COST WOULD GO DOWN? THE ANSWER WAS NO. I HAD NO CHOICE BUT TO PAY THE $150 AS TRYING TO GET OUT OF MY CONTRACT WAS NOT A GOOD OPTION SINCE I WOULD HAVE TO BUY OUT MY EXISTING CONTRACT, WHICH WAS TOO EXPENSIVE. I FELT THAT I WAS TOLD INACCURATE AND INCOMPLETE INFORMATION WHEN I SIGNED THE CONTRACT AS I WAS VERY CLEAR WHEN I EXPLAINED MY CONCERNS AND NEEDS TO THE REPRESENTATIVE. AS A CONSUMER, I DIDN'T KNOW IF I HAD ANY RIGHTS TO DISPUTE WHAT I THOUGHT WAS AN UNFAIR POLICY. NOR DID I KNOW TO WHOM I COULD COMPLAIN.
3. THIS IS MY PERSONAL EXPERIENCE AND AN EXAMPLE OF WHY CONCISE PRICING AND EXPERTISE IN ACCESSIBILITY IS SO IMPORTANT TO CANADIANS WITH DISABILITIES.

LUI GRECO

1. WIRELESS DEVICES, AS WE ALL KNOW, ARE TRANSFORMING THE WAY WE DO BUSINESS, COMMUNICATE AND ENTERTAIN OURSELVES. THE PACE AT WHICH THIS TECHNOLOGY HAS BECOME AN ELEMENT IN ALMOST EVERY ASPECT OF OUR DAILY LIVES COULD HARDLY HAVE BEEN IMAGINED EVEN A DECADE AGO.
2. AS SOMEONE WHO HAS BEEN BLIND FROM BIRTH, I LOOK TO THESE INNOVATIONS AS AN OPPORTUNITY FOR A MORE LEVEL PLAYING FIELD. YET DESPITE THE BREAKNECK PACE AT WHICH WIRELESS DEVICES HAVE BEEN ADOPTED BY THE GENERAL PUBLIC, AS A PERSON WITH A DISABILITY, I REMAIN BEHIND THE PACK. IT WASN'T UNTIL THE LAST HALF OF THE FIRST DECADE OF THIS CENTURY THAT SOMEONE WHO WAS BLIND COULD EVEN CONTEMPLATE ACQUIRING AN ACCESSIBLE DEVICE AS A RETAIL TRANSACTION. ALTHOUGH ACCESSIBLE DEVICES HAVE EXISTED FOR QUITE SOME TIME PRIOR TO 2005, THEY TENDED TO BE SPECIALTY PRODUCTS TYPICALLY SOLD BY OFFSHORE COMPANIES. MY ONLY OPTION, PRIOR TO 2006 OR SO WAS TO CROSS MY FINGERS AND HOPE THAT THE DEVICE I PURCHASED WOULD AT MINIMUM, ALLOW ME TO MAKE TELEPHONE CALLS. YET, THE PRICE OF THE EQUIPMENT ALWAYS INCLUDED MANY FEATURES, OPTIONS AND ENHANCEMENTS, WHICH WERE UNAVAILABLE TO ME AS A BLIND PERSON.
3. FORTUNATELY, AS MORE AND MORE MANUFACTURERS HAVE BEGUN TO REALIZE THE POTENTIAL MARKET FOR ACCESSIBLE DEVICES AND REGULATIONS IN OTHER JURISDICTIONS IMPROVED, MY OPTIONS ARE INCREASING. ALTHOUGH WE'RE NOT QUITE THERE YET, I'M ABLE TO WALK INTO A RETAIL OUTLET, PUT DOWN MY MONEY AS YOU WOULD AND PURCHASE A DEVICE FOR THE SAME PRICE AS ANYONE ELSE. IN FACT, I DID JUST THAT LAST WEEK.
4. HOWEVER, NOT ONLY IS MY LEARNING CURVE STEEPER GIVEN THAT MOST PRODUCT MANUALS ARE DESIGNED WITH SIGHTED INDIVIDUALS IN MIND, BUT I MUST NOW LEARN BOTH THE OPERATING SYSTEM OF MY DEVICE AND HOW TO WORK THE TEXT TO SPEECH SOFTWARE WHICH MAKES THE DEVICE ACCESSIBLE. PERSONALLY, I EMBRACE NEW TECHNOLOGY AND SOME MAY CONSIDER ME AS HAVING AN ABOVE AVERAGE ACUMEN WHEN IT COMES TO MAKING ELECTRONICS WORK. MANY OF MY COLLEAGUES, BOTH BLIND AND SIGHTED, ARE NOT SO INCLINED.
5. EVEN AS SOMEONE WITH AN APTITUDE FOR TECHNOLOGY, I DO NOT HAVE THE LUXURY OF CONSULTING WITH THE VENDOR WHO HAS SOLD ME MY DEVICE FOR DIRECTIONS IN HOW TO WORK THE ACCESSIBILITY SOFTWARE, WITHOUT WHICH MY PURCHASE IS USELESS. I MUST TURN TO THE VIRTUAL WORLD TO HELP ME LEARN HOW TO TAKE FULL ADVANTAGE OF THE EQUIPMENT I'VE PURCHASED. YES, THERE IS AN ABUNDANCE OF ELECTRONIC RESOURCES, BUT AS WITH ANYTHING ON THE INTERNET, FINDING ACCURATE AND USABLE INFORMATION ISN'T ALWAYS "JUST A CLICK AWAY". THEN THERE'S THE CHALLENGE OF FINDING A FULLY ACCESSIBLE SITE, WHICH CAN PROPERLY SUPPORT THE ASSISTIVE TECHNOLOGY.
6. SO WHAT ARE MY CHOICES WHEN I SPEND $700 ON A WIRELESS DEVICE? I CAN EITHER PRAY THAT IN TIME I'LL FIND THE MAGIC NUGGET OF KNOWLEDGE NECESSARY TO MAKE IT WORK AS ADVERTISED OR BRING IT BACK WITHIN THE BUYER'S REMORSE GRACE PERIOD. WHEN I EXERCISE THE LATTER OPTION, WHO LOSES? EVERYONE. I, AS A CONSUMER WITH A DISABILITY, FEEL DISENFRANCHISED BECAUSE, YET AGAIN, I'M ON THE OUTSIDE LOOKING IN.
7. THERE IS NO ONE SIZE FITS ALL SOLUTION FOR PERSONS WITH DISABILITIES. JUST AS WITH THE COMMUNITY AT LARGE, WE ALL LEARN DIFFERENTLY AND AT OUR OWN UNIQUE PACE. I UNDERSTAND THE NEED FOR CONTRACTUAL OBLIGATIONS, A DAILY REALITY WHEN PURCHASING WIRELESS DEVICES. WHAT WOULD BENEFIT ME, AS A PERSON WITH A DISABILITY, WOULD BE TO INTRODUCE A LONGER "HONEY-MOON" GRACE PERIOD AS PART OF THE CONTRACT.
8. ALTHOUGH I'M NOT ABLE TO SPECIFICALLY SAY HOW LONG IS LONG ENOUGH, I CAN EMPHATICALLY DECLARE THAT FOR THE AVERAGE PERSON LEARNING BOTH ACCESSIBILITY SOFTWARE AND THE NUANCES OF A NEW DEVICE, TWO WEEKS IS NOWHERE LONG ENOUGH.

CHRISTINE ROBBINS

1. CNIB'S STAFF OFTEN HEARS FROM OUR CLIENTS REGARDING THE CHALLENGES THEY FACE WHEN A PRODUCT OR SERVICE THAT WAS ACCESSIBLE WHEN THEY PURCHASED IT BECOMES INACCESSIBLE WHEN THE PROVIDER UPGRADES THE PRODUCT OR SERVICE.
2. I WILL SHARE WITH YOU ON CLIENT'S EXAMPLE TO HIGHLIGHT WHY RECOMMENDATION 4: APPROPRIATE CANCELLATION IS IMPORTANT TO CANADIANS WITH DISABILITIES.
3. WHILE TRAVELLING FOR WORK, ONE OF OUR CLIENTS USES SHAW WEBMAIL TO CHECK HER PERSONAL E-MAIL ON HER PHONE OR LAPTOP. ON ONE SUCH OCCASION SHAW UPDATED THEIR WEBMAIL VERSION IN A MANNER THAT RENDERED IT INACCESSIBLE. HER SCREEN READING SOFTWARE COULD NO LONGER READ HER E-MAILS AND THERE WAS NO ALTERNATE WAY FOR HER TO CHECK HER E-MAIL. WHEN SHE RETURNED HOME FROM HER WORK TRIP SHE CALLED THE COMPANY AND THEY WERE ABLE TO FIND A SOLUTION. HOWEVER, THIS LEFT HER UNABLE TO COMMUNICATE ELECTRONICALLY FOR SEVERAL DAYS.
4. IN THIS CASE, A SOLUTION WAS FOUND HOWEVER, IF A WIRELESS SERVICE PROVIDER CHANGED THEIR SERVICE IN A WAY THAT MADE THE SERVICE IN ACCESSIBLE TO A BLIND AND PARTIALLY SIGHTED CANADIANS, I.E. ACCESS TO ONLINE ACCOUNT INFORMATION, THEY SHOULD HAVE THE OPTION OF GETTING OUT OF THE CONTRACT REGARDLESS OF ITS LENGTH AND WITHOUT PENALTY.

GARY SAXON

1. I WOULD LIKE TO REINFORCE THE COMMENTS OF CATHERINE ROBERTS WITH MY OWN EXPERIENCE AS A SENIOR CITIZEN. I KNOW FROM MY OWN EXPERIENCE AND THAT OF OTHER SENIORS VISION LOSS INCREASES WITH AGING, AS DOES HEARING LOSS. THIS REALITY HAS A DIRECT IMPACT ONE'S ABILITIES TO USE VARIOUS FEATURES IN A SERVICE PLAN. IF A PERSON CAN NO LONGER USE SERVICES IN A CONTRACT AS A RESULT OF BECOMING DISABLED IN SOME WAY, THEY SHOULD BE ABLE TO TERMINATE THEIR PLAN.

ROBERT CORBEIL

1. THE CANADIAN HARD OF HEARING ASSOCIATION REGULARLY PASSES ON QUESTIONS TO OUR EXPERTS AT MAC FROM HARD OF HEARING CLIENTS NEEDING HELP RESOLVING BOTH TELECOMMUNICATIONS AND BROADCASTING ISSUES. SUCH ISSUES ARE NOT EASILY RESOLVED AND OUR CLIENTS REQUIRE SOMEONE WHO HAS AN EXPERTISE IN ACCESSIBLE DEVICES, ACCESSIBILITY POLICIES, BROADCAST AND TELECOMMUNICATIONS ENGINEERING AND MORE. EACH CANADIAN WHO LIVES WITH A DISABILITY IS AN EXPERT ON WHY THEY NEED ACCESSIBILITY, BUT GETTING THAT ACCESSIBILITY REQUIRES TRUSTED EXPERTS WHOSE INTERESTS ARE SQUARELY IN LINE WITH THOSE OF OUR COMMUNITY.
2. WHILE WE RECOGNIZE THE COMMISSION HAS, IN THEIR PROPOSED DRAFT OF THE CODE, ESTABLISHED A PROCESS FOR COMPLAINTS. WE FEEL IT IS INSUFFICIENT TO MEET THE NEEDS OF PEOPLE WITH DISABILITIES AS THE STAFF AND AGENCIES THAT DEAL WITH THESE COMPLAINTS DO NOT HAVE THE REQUISITE KNOWLEDGE.
3. CANADIANS WITH DISABILITIES NEED EXPERT ADVOCATES WHO UNDERSTAND THE DISABILITY WITHIN THE CONTEXT OF ENFORCEMENT STRUCTURE. THEY NEED A TRUSTED CENTRAL SOURCE THAT CAN BOTH EXPLAIN TO THEM WHAT IS HAPPENING IN THE AREA OF THEIR CONCERN AS IT AFFECTS ACCESSIBILITY, WHY OR WHY NOT THE WSP IS ACCOUNTABLE AND ENSURE PROPER REPRESENTATION OF THEIR CONCERNS. WE STRONGLY RECOMMEND THAT AN OFFICE OF DISABILITY ISSUES BE ESTABLISHED FOR THAT PURPOSE.

MICHEL DAVID:

1. AS A HARD OF HEARING INDIVIDUAL IN CHARGE OF THE OTTAWA OFFICE OF THE CANADIAN HEARING SOCIETY, I WORK, EVERY DAY ON THE FRONT LINE OF DEAF, DEAF BLIND AND HARD OF HEARING INDIVIDUALS. OUR 27 OFFICES ACROSS ONTARIO ARE THERE TO HELP THESE PEOPLE DEAL WITH THE CRISIS OF SUDDEN HEARING LOSS, SUPPORTING JOB PLACEMENT, HEARING AIDS AND OTHER AIDS THAT ALLOW THEM TO FULLY PARTICIPATE IN EVERY DAY CANADIAN SOCIETY. WE PROVIDE A WIDE VARIETY OF ACCESSIBILITY SERVICES, HEARING HEALTHCARE SERVICES, COUNSELLING AND EDUCATION PROGRAMS...
2. IT IS NOT GOING TO SURPRISE ANYONE HERE THAT CANADIANS WITH DISABILITIES ARE GOING WIRELESS IN THE SAME WAY AS ALL OTHER CANADIANS.
3. BUT FOR THOSE WITH DISABILITIES, TRYING TO GET CLEAR INFORMATION, ANSWERS TO QUESTIONS AND TO JUST DIG THROUGH THE WEBSITE OF SERVICE PROVIDERS FOR INFORMATION IS A NIGHTMARE AT TIMES. I HAVE GIVEN UP MORE THAN ONCE AND ASKED MY WIFE TO CALL OR GO TO THE NEAREST STORE TO TRY AND CLARIFY AN ISSUE. ACCESSIBLE CONSUMER INFORMATION IS CONSISTENTLY NOT AVAILABLE IN THE RETAIL STORES, ON-LINE OR OVER THE PHONE. I DO UNDERSTAND WHY THIS MIGHT BE THE CASE AS EACH AND EVERY WIRELESS SERVICE PROVIDER WOULD HAVE TO BE CONSTANTLY TRAINING AND UPDATING A LARGE STAFF TO ADDRESS THEIR OWN CHANGING SERVICES AND PRODUCTS AS WELL AS THOSE THE ACCESSIBLE DEVICES INDUSTRY, AN INDUSTRY THEY KNOW VERY LITTLE ABOUT.
4. CANADIANS WITH DISABILITIES THEREFORE, NOT ONLY NEED A CENTRAL SOURCE FOR ENFORCEMENT, THAT SAME SOURCE COULD ELIMINATE BOTH THE REDUNDANCY OF EACH WSP HAVING TO DEVELOP EXPERTISE IN THIS AREA BY ESTABLISHING A CENTRAL SOURCE FOR ACCESSIBLE INFORMATION AND ENFORCEMENT EITHER WITHIN THE CRTC OR AT AN ARMS LENGTH AGENCY.

CONCLUSION - BEVERLEY MILLIGAN

1. TO CONCLUDE MR. CHAIRMAN, CANADIANS WITH DISABILITIES HAVE AN UNIQUE RELATIONSHIP WITH WIRELESS DEVICES. IT HAS DRAMATICALLY OPENED UP THE OPPORTUNITY TO COMMUNICATE, BUT THOSE SAME INDIVIDUALS ARE FORCED TO PAY FOR SERVICES THEY SIMPLY ARE INCAPABLE OF USING. THEY'RE NOT GIVEN THE TIME OR SUPPORT TO PROPERLY TEST NEW EQUIPMENT FOR COMPATIBILITY WITH THEIR NEW DEVICES AND THEY HAVE NO CENTRAL SOURCE TO GO TO FOR SUPPORT AT THE RETAIL LEVEL. AS THE RANGE OF WIRELESS ACTIVITIES CONTINUES TO EXPAND, THE GAP BETWEEN FUNCTION AND ACCESS WILL WIDEN, UNLESS STEPS ARE TAKEN TO INTRODUCE A WIRELESS CODE OF CONDUCT THAT SUPPORTS THE NEEDS OF ALL WIRELESS USERS WE FEEL THE TECHNOLOGY GAP WILL WIDEN AND A SIGNIFICANT SEGMENT OF THE CANADIAN POPULATION WILL BE LEFT BEHIND AND FURTHER ISOLATED...
2. WE HAVE PROVIDED A FEW EXAMPLES OF THE THOUSANDS OF STORIES, AGAIN AND AGAIN TOLD TO WIRELESS SERVICE PROVIDER REPRESENTATIVES AT STORES AND THROUGH CALL CENTRE OPERATORS. THERE HAS BEEN NO VOLUNTARY ACTION ON THE PART OF THE WIRELESS SERVICE PROVIDERS TO ADDRESS THESE IMPORTANT ISSUES.
3. THEREFORE, WE RESPECTFULLY REQUEST THAT, AS A TOP PRIORITY, THE COMMISSION INCLUDE A SECTION IN THE MOBILE WIRELESS CODE OF CONDUCT TO ADDRESS THE WIRELESS USAGE RIGHTS OF CANADIANS WITH DISABILITIES.
4. THANK YOU; WE WELCOME A DISCUSSION WITH YOU.