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Brief in Support of An Application to Amend Voiceprints Broadcasting License

Part I - Introduction

  1. The National Federation of the Blind: Advocates for Equality (NFB:AE), is pleased to support the application of the National Broadcast Reading Service Incorporated (NBRS) to amend the broadcasting license held by its Voiceprint Division to allow for the distribution of the Voiceprint Service as a secondary audio program (SAP) service on all Class 1 and Class 2 broadcasting distribution undertakings.

  2. The NFB:AE was founded in 1992 as a consumer group primarily made up of blind, vision-impaired and deaf-blind Canadians. Currently, the NFB:AE is a registered Canadian charity which has the following goals: (a) to change society's attitudes about blindness and vision-impairment through public education, advocacy and other forms of education; (b) to protect the existing rights and freedoms currently held by blind, vision-impaired and deaf-blind Canadians; (c) to enhance the rights, freedoms and access to services for blind, vision-impaired and deaf-blind Canadians; and (d) to otherwise enhance the quality of life and experiences for blind, deaf-blind and vision-impaired Canadians.

  3. The Voiceprint Service is of immeasurable importance to blind and vision-impaired Canadians. Without this service, blind and vision-impaired Canadians would not have the same access to current information contained in newspapers and other periodicals as others in society at a reasonable cost. In addition, Voiceprint has provided a method of widely distributing information that may be of unique importance to Canadians who are blind or vision-impaired.

Throughout the following sections of this submission, the NFB:AE will set forth why it is important for blind and vision-impaired Canadians to have the benefit of the Voiceprint Service so that they can participate more effectively within Canadian society.

Part II: Relevant Legislative Provisions

  1. The Canadian Radio-Television and Telecommunications Commission is bound by the provisions of the Broadcasting Act, S.C. 1991, Chap. 11, as amended. Section 3(1)(d)(iii) provides: 3(1) It is hereby declared as the broadcasting policy for Canada that: ... (d) the Canadian broadcasting system should ... (iii) through its programming and the employment opportunities arising out of its operations, serve the needs and interests, and reflect the circumstances and aspirations, of Canadian men, women and children, including equal rights, the linguistic duality and multicultural and multiracial nature of Canadian society and the special place of aboriginal peoples within that society, ...

  2. In addition, section 3(1)(p) provides that broadcasting undertakings are required to provide programming that is accessible to disabled persons as resources become available for the purpose.

  3. These provisions, when read together, support the notion that services such as Voiceprint should be available to all Canadians who are unable to read print because of a disability irrespective of where they live in Canada.

  4. In the past, Voiceprint was carried by different cable companies using different SAP channels. To ensure that Voiceprint is easily located on all cable systems by Voiceprints viewers, Voiceprint has entered into an agreement with the CBC Newsworld channel to carry its service on Newsworlds SAP channel. However, it lacks the ability to carry out the terms of this agreement without sufficient funding by way of increased cable rates paid by Canadian subscribers. If the one cent per month charge addition to the cable bill of Canadian cable subscribers is not endorsed by the Commission, there is good reason to doubt that Voiceprint will continue to exist. This would be a tremendous blow since there are no other providers in the Canadian broadcasting system which offer a similar service to that which Voiceprint provides. In the absence of a functioning service such as Voiceprint, it is submitted that the Commission would not be honouring its obligations by enforcing the goals and objectives of the Canadian Broadcasting Act to support the important and specialised services provided by Voiceprint.

Part III: Why Voiceprint Is So Important

  1. The Voiceprint Service is of tremendous importance to blind and vision-impaired Canadians. Without this service, these individuals would not be able to access information published in newspapers or periodicals at a reasonable cost. While these publications are currently available on the Internet, most blind and vision-impaired Canadians do not have access to a computer because of the unequal access to funding support for such equipment from provincial governments across Canada. For those who do have access to computers, most newspapers and periodicals do not provide complete access to their articles on their websites. In some cases where full access is provided, the user is required to pay a fee per article in order to access the full text of the information they wish to review.

  2. The Voiceprint Service provides no such barriers. Instead of charging a fee for service based on the type of information that is reviewed, volunteer readers read from a variety of publications, including the Globe & Mail, the National Post, the Toronto Star, Scientific American, Macleans and others, at various times during the day. Blind and vision-impaired Canadians can listen to the articles in their areas of interest by tuning into Voiceprint at certain times of the day. Since Voiceprint is carried as an SAP service now, the only equipment that a blind or vision-impaired Canadian would require to access this service would be a stereo television and access to a cable or home satellite system. In addition, some cable companies have allocated a frequency to Voiceprint on FM Cable.

  3. Many blind and vision-impaired Canadians are required to review newspapers on a daily basis as part of their job requirements. Voiceprint provides an immeasurably valuable service in this regard, since an individual who is blind or vision-impaired would have access to many news articles and other business-related publications such as stock market summaries on the day that they are released. This kind of access to printed news media was unheard of prior to Voiceprints existence. It is the only service of its kind where blind and vision-impaired Canadians can access information published in newspapers and periodicals in a timely fashion without having access to a computer. Without this service, the representation of blind and vision-impaired Canadians in the Canadian workforce will not likely improve. This is especially so in those occupations where it is imperative that the individuals have access to current information in newspapers and periodicals to perform their job duties. For example, it would be impossible for a blind banker to monitor basic trends within the banking industry without having access to publications such as the Report on Business.

  4. Voiceprint is also of immeasurable benefit to senior citizens who are blind and vision-impaired. Many of these individuals have lost their vision after they have become senior citizens. Accordingly, it may not always be practical for them to acquire the new skills associated with learning how to use a computer, synthetic speech or large print devices to read information contained in newspapers and other publications. These individuals have always had access to this information throughout their lives and have come to take it for granted to some extent. It would be most unfortunate if they were deprived of the opportunity to have access to this kind of information on account of their vision loss.

Part IV: The Importance of the One Cent per Month per Customer Surcharge

  1. NFB:AE submits that the one cent per month per customer surcharge is reasonable. It is not an onerous burden to ask Canadians to bear to ensure that blind and vision-impaired Canadians have access to the Voiceprint Service. Canadians already pay for disability-based access in other areas that are regulated by the CRTC. For example, each Canadian pays thirteen cents per month on her/his phone bill to finance the costs of the Bell Relay Service, a service which allows deaf and hard of hearing Canadians to communicate with others using telephones and telephone devices for the deaf. This thirteen cent per month surcharge has allowed deaf Canadians to participate more effectively within Canadian society by allowing them to communicate with everyone else.

  2. Similarly, a one cent per month per customer surcharge would allow blind and vision-impaired Canadians to access information so that they can communicate with others knowledgeably, participate more effectively within the workforce and otherwise make contributions to Canadian society.

  3. The Broadcasting Act provides in section 3(1)(d)(iii) that through its programming efforts, the broadcasting system is required to serve the needs and interests and reflect the circumstances and aspirations of all Canadians. This section also refers to the importance of reflecting the needs and interests of individuals in a manner of equality. One way that this provision can be used to guarantee such access for blind and vision-impaired Canadians is to provide a vehicle within the broadcasting system to have information that is only available in a printed form reproduced into an audio format which can be readily understood and absorbed by blind and vision-impaired Canadians. Without this, blind and vision-impaired Canadians will not have access to current information which others take for granted.

Part V: What Happens If the License Amendment Sought by the NBRS is Refused?

  1. If the amendment to the Voiceprint License is refused by the Commission, it is almost certain that Voiceprint will not be able to continue its operations. As a result, a significant group in society will be denied access to printed information in an audio format.

  2. If Voiceprint was unavailable, groups such as the NFB:AE will have to look to other sources to obtain this kind of service for their members. No for-profit producers have to date come to the forefront to provide information to blind and vision-impaired Canadians in an audio format in the same fashion as Voiceprint has for a number of years. If Voiceprint suspends its operations, groups such as the NFB:AE may have to resort to advocacy efforts through the courts and through the Canadian Human Rights Commission to require cable companies and other home satellite service providers to provide a Voiceprint type service. A further spin-off may be that blind and vision-impaired Canadians would have to commence proceedings against individual newspapers or publishers of periodicals before provincial human rights commissions to obtain the text of these publications at the same time and at the same cost as other subscribers.

Furthermore, if Voiceprint is forced to suspend its operations, the Commissions decision not to grant the one cent surcharge may be subject to attack by blind and vision-impaired Canadians under section 15 of the Canadian Charter of Rights and Freedoms, since their ability to participate within society may be significantly compromised.

  1. It is clear that a proliferation of litigation of the types described above would not be in the public interest. Most Canadians would likely agree that a one cent per month per customer surcharge is a small price to pay to substantially reduce this kind of activity, since it is the most cost effective method of providing access to newspapers and periodicals for blind and vision-impaired Canadians that is currently in existence. It is also a very reasonable method to ensure that blind and vision-impaired Canadians are provided with access to the important information contained in newspapers and periodicals.

  2. Section 9 of the Broadcasting Act, supra, requires all individuals wishing to operate a television station to obtain a license from the CRTC. When license applications are submitted, the applicant must satisfy the Commission that the type of programming that the applicant intends to provide meets the obligations imposed by Section 3(1) of the Broadcasting Act.

  3. The precedent has already been set by the Commission to require Canadians to pay additional fees on their cable bills to subsidise cable channels which a given individual may never choose to watch or support. The CRTC has recognised the importance of licensing specialty channels to give groups who have been traditionally disadvantaged because of gender, race, national or ethnic origin or disability, the opportunity to contribute to the diversity of Canadian culture by allowing these groups to show television programs that primarily benefit the disadvantaged group. A decision not to grant the one cent surcharge would serve to increase the degree of disadvantage that blind and vision-impaired Canadians already experience in their interactions with the rest of society.

  4. The members of NFB:AE view access to printed information in alternate formats, such as Braille, large print, information produced on audio cassette or in an audio format, intervention services for deaf-blind persons and electronic information stored on computer diskettes as being a fundamental right to be enjoyed by all blind, vision-impaired and deaf-blind Canadians. NFB:AE will be monitoring these proceedings very carefully to ensure that the interests of its members who use Voiceprint to access basic information in an audio format are carefully and effectively preserved by the Commission. If public hearings are held, NFB:AE requests that it be given standing to present its views to the Commission during the public hearing process.

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