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CRTC Intervention Re NBRS Specialty Channel

Thursday, February 1, 2007

Office of the president: #304 - 192 Jarvis Street Toronto, ON M5B 2J9
Tel: 416-941-1547

February 18, 2007

Ms. Diane Rhéaume
Secretary General
Canadian Radio-television and
Telecommunications Commission
1 Promenade du Portage
Les Terrasses de la Chaudière
Central Building
Gatineau, Quebec K1A 0N2

Dear Ms. Rhéaume:

Re: Application 2006-1579-2, The Accessible Channel


  1. The Alliance for Equality of Blind Canadians /L'Alliance pour l'ÉgalitÉ des Personnes Aveugles du Canada (formerly the National Federation of the Blind: Advocates for Equality) is writing to oppose the establishment of a specialty DVS channel and respectfully requests the CRTC to reject the application filed by NBRS. Since Descriptive Video Service (DVS) plays an important part in assuring equal access to, and full enjoyment of television by Canadians who are blind and partially sighted, the AEBC also strongly urges the CRTC to exert leadership by mandating and assisting our community to harness the needed energy and resources to develop alternative, mainstream  approaches to the provision of DVS programming, some of which are proposed in this intervention.
  2. The AEBC, formerly known as the NFB:AE, is a national, not for profit organization, whose membership is comprised of Canadians who are blind, deaf-blind and partially sighted. AEBC's work focuses on conducting public awareness and providing policy advice on a wide range of blindness-related issues of concern to our community.
  3. Both the AEBC and its predecessor organization, the NFB:AE fully support, and are anxious to see an expansion of the availability of DVS programming on all regular television channels.
  4. The Broadcasting Act states, at paragraph 3 (1): "Programming accessible by disabled persons should be provided within the Canadian broadcasting system as resources become available for the purpose."
    The AEBC believes new resources should be used to expand the amount of DVS programming available on regular channels, rather than creating a separate channel.
  5. The AEBC wishes to restate part of its response to Broadcasting Notice of Public Hearing CRTC 2006-5, Review of certain aspects of the regulatory framework for over-the-air television: "The AEBC asserts that Canada's Charter of Rights and Freedoms and the Canadian Human Rights Act were enacted to give bodies such as the CRTC full authority to regulate aspects that come under their respective authority and jurisdiction." With this in mind, the AEBC expects the CRTC to apply its regulatory authority in a vigorous and proactive manner to all aspects under its jurisdiction, including regulating in a more proactive manner the expansion of DVS programming throughout Canada.
  6. Members of both the AEBC and NFB:AE have adopted resolutions that support the full integration of Canadians who are blind, deaf-blind and partially sighted into all aspects of regular community life. As such, the AEBC believes that persons with disabilities are best served, and have the right to be served through the regular system, rather than through specially created separate services. See Appendix "A" for the text of some of these Resolutions.
  7. The Deaf community, with it's regard for and appreciation of Deaf culture, didn't turned to a proposed dedicated captioned channel but rather focused on and succeeded in obtaining captioning on regular television programming. Canadians who are blind, deaf-blind and partially sighted must have the same right to access regular programming, and believe the CRTC must use its regulatory-making authority to help us achieve this right throughout Canada.
  8. "Universal design" has been defined as: "The design of products and environments to be usable by all people, to the greatest extent possible, without adaptation or specialized design."
  9. Canada's Charter of Rights and Freedoms limits the ability of governments to pass laws or take actions that discriminate or infringe on human rights. The AEBC believes that Canada's Charter of Rights and Freedoms, and the Canadian Human Rights Act mandate, and good business sense demand that principles of universal design govern all deliberations of the CRTC. These principles should result in all regulatory bodies, including the CRTC, to focus on promoting mainstream services and products that are available to all Canadians, and that alleviate the need to develop separate delivery mechanisms or products that require special adaptation. For further details on aspects of Universal Design, see Appendix "B" which forms a part of this Brief.
  10. The AEBC believes the establishment of this proposed "special service" will be used by the regular broadcasting system as an excuse to further drag its feet, rather than encouraging broadcasters to increase the amount of DVS programming they provide. Such an outcome would only further violate our rights to access regular programming.
  11. By way of analogy, in the area of "special services," history reveals, the presence of CNIB's Employment department nationwide was used by many other service providers as a reason not to deal with blind Canadians in their own programs that were available to other job-seekers locally. Similarly, the presence of the CNIB Library was used until recently as an assumption that the reading and information needs of Canadians who are blind, deaf-blind and partially sighted were already adequately taken care of, thereby removing the need for public libraries to serve us, as they do all other members of their community.
  12. Since there are differences in how the digital cable and satellite systems implement access to the SAP feature, this may further reduce the access to DVS Programming.  AEBC believes that the CRTC should use this opportunity to take a leadership role in defining how DVS programming should be accessed on the digital broadcast system.  Because of the increased number of channels on the digital system, We propose that digital providers add the necessary channels to provide programming with open DVS.  For example, Bell ExpressView provides DVS programming in an open format on their service.  They also provide a daily audio guide to what programming is available in DVS and what channel it is on.
  13. In today's society where sighted television viewers have the option of choosing from over 200 or 300 stations. Why should blind Canadians be expected to be satisfied with this kind of segregated option? This is the practical reason why we are urging the CRTC to help us gain access to DVS programming on all channels, something we also believe we have every right to expect.
  14. In conclusion, rather than establishing a new "special" service, the AEBC believes that resources and energy should be devoted to finding new solutions that will enhance access to regular programming. We ask the CRTC to mandate and to help us work with broadcasters to take steps to expand the level of DVS programming they provide.


  • 99-16: The NFB:AE supports the increased availability of described video services during prime time media broadcasts. We encourage the CRTC to ensure that 100% of prime time broadcasts are described by the year 2003. We insist all cable providers and other television broadcasters be mandated to ensure that all other services are accessible to people who are blind. Services such as Community information channels, television commercials etc.
  • 2002-03: The NFB:AE shall advocate before the CRTC, Industry Canada and any other public body in support of the propositions that:
    1. All features of Digital Audio Broadcasting receivers shall be accessible to people who are blind or vision-impaired; and
    2. To ensure that digital broadcasters develop a universal method of transmitting their data to ensure that accessibility features built into digital audio broadcasting receivers remain effective.
  • 2006-08: Charity vs. Rights
    therefore, be it resolved that the AEBC advocate for a more mainstream model of service delivery provided by governments as a matter of right, rather than charity.
  • 2006-15: Access to Secondary Audio Programming (adopted by the board and will go to the members in 2007 for ratification)
    -Whereas, descriptive video soundtracks are broadcast by cable companies on the Secondary Audio Programme (SAP) of television channels; and
    -Whereas, access to SAP is usually obtained through the television, digital terminal or VCR's visual menu; and
    -Whereas, these menus are not accessible to blind people who require access to SAP;

    Be it resolved that the AEBC take steps to encourage cable TV companies and TV manufacturers to provide a dedicated "SAP" button on the units' remote controls.


The design of products and environments to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design.
Universal Design Definition:
  1. Principle One: Equitable Use

    The design is useful and marketable to people with diverse abilities

    • Provide the same means of use for all users: identical whenever possible; equivalent when not.
    • Avoid segregating or stigmatizing any users.
    • Provisions for privacy, security, and safety should be equally available to all users.
    • Make the design appealing to all users.
  2. Principle Two: Flexibility in Use

    The design accommodates a wide range of individual preferences and abilities.

    • Provide choice in methods of use.
    • Accommodate right- or left-handed access and use.
    • Facilitate the user's accuracy and precision.
    • Provide adaptability to the user's pace.
  3. Principle Three: simple and intuitive

    Use of the design is easy to understand, regardless of the user's experience, knowledge, language skills, or current concentration level.

    • Eliminate unnecessary complexity.
    • Be consistent with user expectations and intuition.
    • Accommodate a wide range of literacy and language skills.
    • Arrange information consistent with its importance.
    • Provide effective prompting and feedback during and after task completion.
  4. Principle Four: Perceptible Information

    The design communicates necessary information effectively to the user, regardless of ambient conditions or the user's sensory abilities.

    • Use different modes (pictorial, verbal, tactile) for redundant presentation of essential information.
    • Provide adequate contrast between essential information and its surroundings.
    • Maximize "legibility" of essential information.
    • Differentiate elements in ways that can be described (i.e., make it easy to give instructions or directions).
    • Provide compatibility with a variety of techniques or devices used by people with sensory limitations.
  5. Principle Five: Tolerance for Error

    The design minimizes hazards and the adverse consequences of accidental or unintended actions.

    • Arrange elements to minimize hazards and errors: most used elements, most accessible; hazardous elements eliminated, isolated, or shielded.
    • Provide warnings of hazards and errors.
    • Provide fail safe features.
    • Discourage unconscious action in tasks that require vigilance.
  6. Principle Six: Low Physical Effort

    The design can be used efficiently and comfortably and with a minimum of fatigue.

    • Allow user to maintain a neutral body position.
    • Use reasonable operating forces.
    • Minimize repetitive actions.
    • Minimize sustained physical effort
  7. Principle Seven: Size and Space for Approach and Use

    Appropriate size and space is provided for approach, reach, manipulation, and use regardless of user's body size, posture, or mobility.

    • Provide a clear line of sight to important elements for any seated or standing user.
    • Make reach to all components comfortable for any seated or standing user.
    • Accommodate variations in hand and grip size. <;li>Provide adequate space for the use of assistive devices or personal assistance.
These Principles of Universal Design address only universally usable design, while the practice of design involves more than consideration for usability. Designers must also incorporate other considerations such as economic, engineering, cultural, gender, and environmental concerns in their design processes. Designers' need guidance to better integrate features that meet the needs of as many users as possible. All Guidelines may not be relevant to all designs.
Please note:

Version 2.0 4/1/97
Compiled by advocates of universal design, listed in alphabetical order:
Bettye Rose Connell, Mike Jones, Ron Mace, Jim Mueller, Abir Mullick, Elaine Ostroff, Jon Sanford, Ed Steinfeld, Molly Story, & Gregg Vanderheiden

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