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Pelmorex's Applications For Weather Network Emergency Notifications

Saturday, July 5, 2003

Public Notice CRTC 2000-71 Item 1


Across Canada 199917720

Deadline for intervention: 5 July 2000.

Sent: July 05, 2000 3:32 PM

To: ''

Cc: ''; ''

Subject: Public Notice 2000 - 71 Application by Pelmorex

Direct Line: (416) 601-7702

Internet Address:

July 5, 2000

Canadian Radio, Television and Telecommunications Commission

Ottawa, Ontario K1A 0N2


Dear Sirs/Mesdames:

Re Public Notice 2000-71 application by Pelmorex to Amend its Licence to Include the All Channel Alert (ACA) System

1. I am writing to you on behalf of the National Federation of the Blind: Advocates for Equality (NFB: AE), to oppose Pelmorex's amendment to its license until such time as the information it seeks to broadcast can be delivered to all cable subscribers in an audio format at the same time as visual messages are displayed.

2. The NFB: AE is a consumer controlled Canadian organization, whose major goals and objectives include the elimination of present and future barriers, preventing the full and equal participation and inclusion of blind, deaf/blind and vision impaired Canadians in all aspects of mainstream society. Access to print information has long been recognized as the most pervasive barrier faced by blind, deaf/blind and vision impaired Canadians, in every conceivable aspect of daily life.

3. The NFB: AE was discouraged to learn that the Applicant was seeking approval of an amendment to its present licence, to include the distribution of an All Channel Alert which would display a message in print on a television screen service (ACA), whenever an Environment Canada alert is warranted, due to unexpected and imminently dangerous environmental conditions posing a threat to persons and property. The Applicant has made no attempts to present the same information in an audio format so that blind and vision-impaired Canadians can receive the same information at the same time as others. This proposed ACA system technology, already endorsed by Environment Canada's Meteorological Service, fails to ensure full and equal access to all Canadian cable and satellite subscribers, by only providing a visual message.

4. In public awareness information about this new service, Environment Canada and others have stated their inability to design an audio message overlay with the ACA system, during the seven years in the design and development phase for this new service. At the same time, Pelmorex Claims to be extremely sensitive to the print handicapped viewing public. This is at best questionable in light of its suggestion that those Canadians, unable to read information presented visually, can continue to receive Environment Canada alerts via conventional radio broadcasts. In NFB: AE's submission, other members of society other than those who are deaf or deaf-blind, would be able to access the same information through conventional radio broadcasts as well. This kind of approach taken by the Applicant weakens rather than strengthens its overall submission to the Commission.

5. Blind, deaf-blind and vision-impaired Canadians are systemically excluded from having pertinent information available to them in a usable format. The effect of the exclusion is even more invidious when the information being presented visually is deemed to be crucial to the safety, well-being and independence of all members of the public. Adding insult to injury, as cable subscribers, print handicapped Canadians would be required to pay a monthly charge of 13 cents per household, for the ACA service even though it is inaccessible to them. This additional charge would not be at all inappropriate if the service was completely accessible for blind and vision-impaired Canadians for the reasons cited by the Applicant in its application materials.

6. The NFB: AE accepts the importance of an environmental alert system to facilitate the preparedness of Canadian citizens in the event of any potential environmental danger or disaster relating to weather, chemical or nuclear in nature. However, NFB: AE would urge the Commission's denial of the approval of Pelmorex's application, proposing an amendment to its present licence, until Pelmorex can assure the CRTC that the service will be provided in a manner that is accessible to blind, vision-impaired and deaf-blind Canadians.

7. There is no reason why, in NFB: AE's view, that the Applicant could not deliver a full service containing audio and visual information. The NFB: AE believes that the technologies are available to bring access to information for blind, deaf/blind and vision-impaired Canadians up to par with the rest of society. All that is required is the commitment to make this fact a reality.

8. A true copy of this intervention has been forwarded to the Applicant, Pelmorex.

9. On behalf of the NFB: AE, I wish to thank the Commission, in advance, in giving serious consideration to the legitimate concerns of print handicapped Canadians on this most important issue.


Yours very truly,

National Federation of the Blind: Advocates for Equality


Robert J. Fenton



c. Pelmorex Media Inc.,

186 Robert Speck Parkway

Mississauga, ON L4Z 3G1