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To the CRTC Re: Consumer bill of rights

Thursday, January 1, 2004

Ms. Diane Rheaume
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa ON K1A 0N2

Sent via e-mail to

Dear Secretary General:

Re: Public Notice (Telecom Public Notice CRTC 2003-6, Consumer bill of rights) Reference: 8665-C12-200307365

1. The National Federation of the Blind: Advocates for Equality (NFB:AE) Wishes to commend the CRTC for initiating the development of a Consumer Bill of Rights, and we are pleased to offer our comments on this important proposal.

2. The NFB:AE is a national non-profit organization OF blind, deaf-blind and partially sighted Canadians, founded in 1992, who have joined together to increase the level of public understanding of issues and concerns affecting our lives and to work collectively to increase our opportunities to participate equally in, and benefit from, all aspects of Canadian society. This must include full access to information and products that are regularly available to the general public in Canada.

3. What rights should be included in a Consumer Bill of Rights?

Any Consumer Bill of Rights should include:

Right of full access to telecommunications for all Canadians, including people with disabilities, which must include accessible products and services that are fully usable by people with disabilities, access to telecommunications promotional information (services - operating instructions, service descriptions containing choices, billing, payment options, terms and conditions), and the right to comparable products and services that are available to the non disabled public, at a comparable cost that a non-disabled person would pay, and the right to the same benefit for that payment.

Right to product design that is usable by all Canadians, and that is compatible with adaptive equipment used by persons with disabilities.

Right to fully accessible and usable services and electronic information provided to the general public, in accordance with established Government of Canada standards, so that they can be of benefit to all Canadians, including citizens with disabilities.

Right to consumer dispute resolution services with the service provider and the regulator, that are simple, explicit, focused and result in a mandatory written decision within a short turnaround time, e.g. 1 month (four weeks).

4. How should a Consumer Bill of Rights be communicated to all Canadians?

The Canadian Human Rights Act (CHRA) prohibits discrimination against persons with disabilities in the provision of goods and services. Providing information about new or amended programs and services in various alternative formats-braille, large print, computer disk and on fully accessible websites--is covered by this provision.

In a practical sense, it is critical that all citizens be fully aware of new regulations, programs, products and services. Thus, a strong onus must be placed on all players to play a positive role in ensuring their information is made available to all Canadians, which must include information in hard copy in various alternative formats and via fully accessible and usable websites, as well as an outreach strategy to communicate the availability of such new information to all members of the public.

By licensee's on their web sites, through bill inserts and media advertisements annually, as well as part of all new service packages in their documentation.

By the CRTC on its web site, as well as references in all publications, public notices and decisions which should include where to obtain copies in multiple formats including those used by citizens who are blind.

By developers and manufacturers of new and improved products, e.g. cellular phones and other telephone equipment.

By the Government of Canada, as part of its ongoing communication with Canadians.

5. how might a Consumer Bill of Rights be amended?

A Consumer Bill of Rights could be amended In the same way as any other regulation is amended, or if it becomes an Act of Parliament. Then, it could be amended through the regular legislative process. In either instance, community input should be sought beforehand.

6. The NFB:AE looks forward to the publication and wide dissemination of the Consumer Bill of Rights, and we hope the CRTC will use it as an additional vehicle for making telecommunications more accessible to and usable by all Canadians, including all Canadians with disabilities.


John Rae

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