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Mr. Robert A. Morin 12 September 2011
Secretary General
Canadian Radio-television and Telecommunications Commission
1 Promenade du Portage
Gatineau, Québec K1A 0N2
Dear Mr. Morin;
Re: Internet Protocol Relay Service (IPRS)
1. The Canadian Association of the Deaf (CAD) is in receipt of the replies of Telus and Rogers to concerns we expressed about Internet Protocol Relay Services in our letter of 2 June 2011, and which the Commission addressed in its letter of 26 July 2011. We appreciate the responses, and provide these comments in reply.
2. Issue #1: Quality of Service. Telus affirms that it has internal measures of quality of service that are applied to IPRS. However, the only example they offer is “whether eighty percent or more of all the incoming calls are answered within twenty seconds or less” (paragraph 7). We would like to know more about all measurements used. We would also like to know who designed the measurements; were Deaf consumers involved? Who is monitoring the measurements? We also request that the Commission require public filings, on a quarterly basis by all providers, of their data on quality of service.
3. Rogers acknowledges our concern that only a single operator is assigned to its IPRS, and states that it has “instructed our IP Relay provider to add additional operators to address any calls during prime hours. These additional operators will be available to handle calls shortly.” (paragraph 5) We are not satisfied with this statement for three reasons:
(i) it does not specify how many “additional operators” will be assigned, nor what constitutes “prime hours”;
(ii) additional operators are needed at all times, not merely during “prime hours”;
(iii) no specific deadline is given for the implementation of this action. What does “shortly” mean?
4. Rogers does not state what measures of quality of service are in place, or indeed whether any such measures are in place, other than that “a typical IP Relay session lasts approximately 20 minutes”. That is not a measurement of quality of service, but merely the average length of calls -- i.e., it is a measurement of quantity, not quality. We remain unsatisfied with Rogers’ response to this concern.
5. Both Telus and Rogers claim that “every indication” is that customers are satisfied with their IPRS. But what indicators are these? Have they actually done a formal survey of users? If a mere lack of complaints is the only such indicator, how can customers complain if they are not even aware that the service exists?
6. Issue #2: Lack of Promotion. Both Telus and Rogers assert that they have promoted their IPRS, with Telus admitting that its efforts in this regard have been limited while it upgrades the service. Rogers expresses surprise that the CAD itself had no awareness of its IPRS until nearly one full year after its launching. We would suggest that the fact we knew nothing about it rather proves our point, i.e., that promotion has been so poor that even this country’s national association of Deaf people was left in the dark about a new service being made available to its constituency.
7. As it happens, the CAD and its staff, members, directors, and advisors are all subscribers to either Telus or Rogers or both. Our Executive Director, for example, is a customer of both of these wireless services and also of Rogers’ cable TV and Internet services; he receives a minimum of five mailings each month from the providers in combination (invoices, service updates, and all promotional material; in Rogers’ case this includes a thick, glossy magazine). Not once has he or any other of our people received a brochure or other promotional material about Rogers IPRS, nor have Telus subscribers outside BC and Alberta received promotional material about Telus IPRS. Even though the service requires IPRS clients to connect to the telco’s website, it is not enough to post information about the service on the website alone. Rogers, for instance, sends each of its Blackberry customers regular emails announcing specials; why is its IPRS not being promoted through such a simple and obvious method? Why has it not been featured in their fancy magazine?
8. Issue #3: Functionality/Design. We are generally satisfied with the responses to our concern about the design of the IPRS. We do repeat, however, that Deaf people themselves should have been involved in the design stage in order to ensure the cleanest design and a functionality best attuned to consumer needs and preferences, right from the start. Involving Deaf people in this manner could have eliminated the issues that eventually required Telus to shut down their IPRS to do upgrades and enhancements. (We note that Bell Canada has had one such “planned interruption” to their IPRS recently, too.)
9. Telus’ defence of their “planned interruptions” overlooks the fact that they are required to maintain equality/equivalency of service at all times. When they perform upgrades and enhancements of their services to regular non-Deaf customers, they do not shut down the entire system, regardless of the timing of the interruption. A bridge to a back-up IPRS should have
been used and should be used in all future interruptions in order to comply with the Commission’s directive to provide 24/7 IPRS. This applies to Bell Canada, too.
10. Issue #4: Hiring of Deaf employees. This concern was originally raised as part of Issue #3 above, but in light of the responses received, we feel now it is better addressed as a separate issue. The CAD’s original letter called upon the Commission to direct all telcos and wireless providers to explain exactly why they continue to refuse to hire Deaf experts to participate in the design, development, testing, and marketing of services and products that are directed to the Deaf community, including IPRS.
11. In their responses, Telus and Rogers both deflect the issue into one of consultation with the community. Both assert that they consult with the community; implicit is the conclusion that this obviates any need or intention of hiring Deaf people as paid employees.
12. The CAD repeats its long-time opposition to the use of unpaid individuals as “rubber-stamp” consultants who are presented after-the-fact with corporate decisions affecting their community and are expected to merely indicate their approval of initiatives already undertaken. The Deaf community has highly-qualified professionals who should be hired as paid in-house employees to direct, create, develop, produce, market, and service all products and services intended to provide access for the Deaf community. Unpaid advisors and consultants are nothing more than exploitive and cynical mechanisms for superficially abiding by the Commission’s directives to include Deaf people in initiatives that concern their access to telecommunications.
13. We request that the Commission direct all telcos and ISP’s to file, on the public record and not in confidence to the Commission alone, data listing how many Deaf and hard of hearing paid employees they have in all departments relating to services and products for Deaf and hard of hearing consumers, both in hard numbers and as a percentage of the total workforce in those departments; and that the data also distinguish between self-defined “Deaf” and “hard of hearing” employees.
14. We also request that the Commission direct all telcos and ISP’s to file on the public record an estimate of the number of employee vacancies expected to arise in the appropriate departments over the course of the next 14 months, and which of these vacancies may be filled by Deaf or hard of hearing applicants.
Sincerely,
James Roots
Executive Director
cc: Interested Parties list
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N
Secretary General
Canadian Radio-television and Telecommunications Commission
1 Promenade du Portage
Gatineau, Québec K1A 0N2
Dear Mr. Morin;
Re: Internet Protocol Relay Service (IPRS)
1. The Canadian Association of the Deaf (CAD) is in receipt of the replies of Telus and Rogers to concerns we expressed about Internet Protocol Relay Services in our letter of 2 June 2011, and which the Commission addressed in its letter of 26 July 2011. We appreciate the responses, and provide these comments in reply.
2. Issue #1: Quality of Service. Telus affirms that it has internal measures of quality of service that are applied to IPRS. However, the only example they offer is “whether eighty percent or more of all the incoming calls are answered within twenty seconds or less” (paragraph 7). We would like to know more about all measurements used. We would also like to know who designed the measurements; were Deaf consumers involved? Who is monitoring the measurements? We also request that the Commission require public filings, on a quarterly basis by all providers, of their data on quality of service.
3. Rogers acknowledges our concern that only a single operator is assigned to its IPRS, and states that it has “instructed our IP Relay provider to add additional operators to address any calls during prime hours. These additional operators will be available to handle calls shortly.” (paragraph 5) We are not satisfied with this statement for three reasons:
(i) it does not specify how many “additional operators” will be assigned, nor what constitutes “prime hours”;
(ii) additional operators are needed at all times, not merely during “prime hours”;
(iii) no specific deadline is given for the implementation of this action. What does “shortly” mean?
4. Rogers does not state what measures of quality of service are in place, or indeed whether any such measures are in place, other than that “a typical IP Relay session lasts approximately 20 minutes”. That is not a measurement of quality of service, but merely the average length of calls -- i.e., it is a measurement of quantity, not quality. We remain unsatisfied with Rogers’ response to this concern.
5. Both Telus and Rogers claim that “every indication” is that customers are satisfied with their IPRS. But what indicators are these? Have they actually done a formal survey of users? If a mere lack of complaints is the only such indicator, how can customers complain if they are not even aware that the service exists?
6. Issue #2: Lack of Promotion. Both Telus and Rogers assert that they have promoted their IPRS, with Telus admitting that its efforts in this regard have been limited while it upgrades the service. Rogers expresses surprise that the CAD itself had no awareness of its IPRS until nearly one full year after its launching. We would suggest that the fact we knew nothing about it rather proves our point, i.e., that promotion has been so poor that even this country’s national association of Deaf people was left in the dark about a new service being made available to its constituency.
7. As it happens, the CAD and its staff, members, directors, and advisors are all subscribers to either Telus or Rogers or both. Our Executive Director, for example, is a customer of both of these wireless services and also of Rogers’ cable TV and Internet services; he receives a minimum of five mailings each month from the providers in combination (invoices, service updates, and all promotional material; in Rogers’ case this includes a thick, glossy magazine). Not once has he or any other of our people received a brochure or other promotional material about Rogers IPRS, nor have Telus subscribers outside BC and Alberta received promotional material about Telus IPRS. Even though the service requires IPRS clients to connect to the telco’s website, it is not enough to post information about the service on the website alone. Rogers, for instance, sends each of its Blackberry customers regular emails announcing specials; why is its IPRS not being promoted through such a simple and obvious method? Why has it not been featured in their fancy magazine?
8. Issue #3: Functionality/Design. We are generally satisfied with the responses to our concern about the design of the IPRS. We do repeat, however, that Deaf people themselves should have been involved in the design stage in order to ensure the cleanest design and a functionality best attuned to consumer needs and preferences, right from the start. Involving Deaf people in this manner could have eliminated the issues that eventually required Telus to shut down their IPRS to do upgrades and enhancements. (We note that Bell Canada has had one such “planned interruption” to their IPRS recently, too.)
9. Telus’ defence of their “planned interruptions” overlooks the fact that they are required to maintain equality/equivalency of service at all times. When they perform upgrades and enhancements of their services to regular non-Deaf customers, they do not shut down the entire system, regardless of the timing of the interruption. A bridge to a back-up IPRS should have
been used and should be used in all future interruptions in order to comply with the Commission’s directive to provide 24/7 IPRS. This applies to Bell Canada, too.
10. Issue #4: Hiring of Deaf employees. This concern was originally raised as part of Issue #3 above, but in light of the responses received, we feel now it is better addressed as a separate issue. The CAD’s original letter called upon the Commission to direct all telcos and wireless providers to explain exactly why they continue to refuse to hire Deaf experts to participate in the design, development, testing, and marketing of services and products that are directed to the Deaf community, including IPRS.
11. In their responses, Telus and Rogers both deflect the issue into one of consultation with the community. Both assert that they consult with the community; implicit is the conclusion that this obviates any need or intention of hiring Deaf people as paid employees.
12. The CAD repeats its long-time opposition to the use of unpaid individuals as “rubber-stamp” consultants who are presented after-the-fact with corporate decisions affecting their community and are expected to merely indicate their approval of initiatives already undertaken. The Deaf community has highly-qualified professionals who should be hired as paid in-house employees to direct, create, develop, produce, market, and service all products and services intended to provide access for the Deaf community. Unpaid advisors and consultants are nothing more than exploitive and cynical mechanisms for superficially abiding by the Commission’s directives to include Deaf people in initiatives that concern their access to telecommunications.
13. We request that the Commission direct all telcos and ISP’s to file, on the public record and not in confidence to the Commission alone, data listing how many Deaf and hard of hearing paid employees they have in all departments relating to services and products for Deaf and hard of hearing consumers, both in hard numbers and as a percentage of the total workforce in those departments; and that the data also distinguish between self-defined “Deaf” and “hard of hearing” employees.
14. We also request that the Commission direct all telcos and ISP’s to file on the public record an estimate of the number of employee vacancies expected to arise in the appropriate departments over the course of the next 14 months, and which of these vacancies may be filled by Deaf or hard of hearing applicants.
Sincerely,
James Roots
Executive Director
cc: Interested Parties list
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N