CRTC Notice of Consultation

CRTC NOC-188-1, Notice of Consultation.

 

In late June, AVLIC requested feedback from members regarding the proposal submitted by the interim board for the composition of the permanent Canadian VRS Board of Directors. To view the proposal and other related documents, please click here.

 

In July, AVLIC hosted a Special Interest Group (SIG) on VRS at the AVLIC conference and we have received comments from various stakeholders. Two points were made clear to us from the SIG and subsequent conversations.

 

The proposal submitted should be changed to state the following:

  1. Interpreter representatives should be a full voting directors on the board (not a non-voting permanent invitee)
  2. Interpreter representatives (MINIMALLY the ASL-English representative) should be an Active member of AVLIC

 


AVLIC wrote a letter to the interim board that outlined these two points and requested the change to the proposal. Unfortunately, the interim board decided not to change their proposal to include AVLIC's requests. The reasons they state for this can be found in their proposal submission to the CRTC (click on the above Related Documents "Proposals" which is the last link under Notice 2014-188).

 

AVLIC has submitted a intervention, addressing the two points above. A copy can be found below.

 

Canadian Radio-television and Telecommunications Commission

Attn: Mr. John Traversy, Secretary General

Les Terrasses de la Chaudière - Central Building

1 Promenade du Portage

Gatineau, Québec

J8X 4B1

 

via: on-line submission to the CRTC[1]

 

Date August 18, 2014

 

Re: Notice No. 2014-188 and Notice no. 2014-188-1 Establishing the structure and mandate of the Video Relay Service Administrator

 

Dear Mr. Traversy,

 

The Association of Visual Language Interpreters of Canada (AVLIC) would like to thank the Canadian Radio-television and Telecommunications Commission (CRTC) for its extensive efforts to review the possibility of implementing Video Relay Services (VRS) in Canada. As strong supporters of the Canadian Deaf community, AVLIC is thrilled to see the positive outcome asserting that services will be provided in American Sign Language (ASL) and la langue des signes québécoise (LSQ) through the Telecom Regulatory Policy CRTC 2014-187 (File numbers: 8665-C12-201303536 and 8665-C12-200807943)[2].

 

In response to the CRTC Telecom Notice of Consultation 2014-188-1[3] and the proposal submitted to the CRTC by the Interim Board of Directors of the VRS Administrator on the structure and mandate of the permanent VRS Administrator[4], AVLIC requests the Commission mandate two requirements that are not currently included in the proposal:

 

1.     That the two (2) “permanent invitees” selected through a process involving interpreter stakeholders[5] should be elevated from “permanent invitees” to “Directors”, including the ability to vote on matters overseen by the Permanent Board.

2.     That it be officially noted those “representing ASL[-English] and LSQ[-French] interpreter organizations” must be an AVLIC-Affiliate Chapter member. Or, at the very least, the ASL-English representative be an AVLIC-Affiliate Chapter member.

 

Sign language interpreters are an integral piece of VRS; therefore, it should be identified that AVLIC members are also stakeholders and must be included in the process of implementing and sustaining VRS in Canada. AVLIC did not submit a proposal[6] to become a service provider, but we assert AVLIC representation, including voting privileges, on the Permanent VRS Administrator’s Board of Directors in the ongoing development and eventual provision of VRS in Canada is imperative.

 

Without having a sign language interpreter holding a Director’s position, we believe it would be unduly limiting for those interpreter representatives to adequately advise and advocate on matters pertaining to the provision of service by the VRS operators. While advising on these matters, under the submitted proposal[7], is possible; the ability to ensure the Board sufficiently addresses matters is not afforded without voting privileges.

The professional sign language interpreters would most effectively:

 

·       OFFER much needed insight regarding the nuances of interpreting;

·       SPEAK to the basic training requirements of the operators providing interpretation;

·       RECOMMEND ongoing professional development for the operators to assure quality controls are maintained;

·       ADDRESS potential occupational health and safety hazards (including the prevention of Repetitive Strain Injury (RSI));

·       PROVIDE a historical prospective about the interpreting profession.

 

AVLIC wants to emphasize that we believe the Permanent Administrator’s Board of Directors would not have the required expertise in the field of sign language interpreting without ongoing consultation. While we concede this need for consultation has been addressed in the Interim Board of Directors of the VRS Administrator’s proposal, AVLIC asserts the limitation of the “permanent invitee” status hinders the representatives from having a real voice of influence at the Board level. This is supported by points from within the Telecom Regulatory Policy CRTC 2014-187[8], including:

 

37. With respect to the structure of the VRS administrator, its Board of Directors must comprise members drawn from [Telecom Service Providers] TSPs and sign language user organizations (both ASL and LSQ), as well as members with other relevant areas of expertise. The VRS administrator must also ensure that staff and any advisory panels that may be struck to advise the Board of Directors include the perspectives of both the ASL and LSQ communities.

 

118. The CHS submitted that any service standards should apply equally to ASL and LSQ, and expressed the importance of imposing minimum screening standards for VRS operators to ensure that they have the necessary qualifications, as VRS calls vary in nature (e.g., medical, legal, 9-1-1) and can require a high degree of interpretation expertise.

 

121. Therefore, the VRS administrator must

·       … ensure that the VRS provider establishes a screening process to ensure that operators are qualified sign language interpreters, meaning that they can interpret effectively, accurately, and impartially, both receptively and expressively, using any necessary specialized vocabulary.

 

135. The VRS administrator must therefore develop VRS privacy and confidentiality provisions, and file them with the Commission for information. Such provisions are to

·       meet existing Commission privacy and confidentiality requirements;

·       be consistent with the AVLIC Code of Ethics and Guidelines for Professional Conduct[9];

·       …

 

As the national organization of and for professional sign language interpreters in Canada, AVLIC was formed in 1979 out of the need for professional networking and the establishment of standards and training for sign language interpreters. The venture was supported by the national Deaf community and service providers for Deaf Canadians[10]. Over the 30+ years that AVLIC has been providing networking and standards assurances to our members and the communities our members serve, we have become the only national representative for sign language interpreting issues in Canada.

 

With respect to our second recommendation: ‘that it be officially noted those “representing ASL[-English] and LSQ[-French] interpreter organizations” must be an AVLIC-Affiliate Chapter member. Or, at the very least, the ASL-English representative be an AVLIC-Affiliate Chapter member’; we believe that as the only national organization representing the interests of sign language interpreters in Canada, AVLIC membership by the ASL–English interpreter representative is imperative. We do, however, acknowledge AVLIC’s representation of LSQ–French and LSQ–ASL interpreters is minimal. We have a structured plan to address this relationship, but the results of the plan are not expected to be in place in time for the Permanent VRS Board formation. With this in mind, we are not at liberty to demand the LSQ interpreter representative be an AVLIC member for the initial Board structuring. We are, however, steadfast in the request that the ASL–English interpreter Director be an AVLIC member.

 

AVLIC was included in the stakeholder consultations conducted by the Interim VRS Board of Directors. We appreciated the opportunity to see the proposed recommendations on the structure and mandate of the Permanent VRS Administrator. We also appreciated the process whereby we were able to ask for clarification and to provide feedback on the submission.

 

During this opportunity, AVLIC was able to share the draft VRS proposal with our membership and to seek feedback from members during our recent AVLIC 2014 biennial conference in Winnipeg, Manitoba. AVLIC hosted a Special Interest Group session on Wednesday, July 9, 2014, whereby AVLIC members and interpreting community stakeholders were able to express their thoughts on the draft VRS proposal. While the session raised questions and comments on the provision of VRS in Canada, the two recommendations outlined above (change from “permanent invitee” to “Director”; and sign language interpreter representatives should be AVLIC-Affiliate Chapter members) were the only comments expressed by stakeholder attendees at the July 9, 2014 session that differs from the Interim VRS Boards’ final proposal.

 

AVLIC shared these two recommendations with the Interim Board. They, in turn, considered the requests; but decided they would not change or edit the submission to reflect these recommendations, as noted in the proposal[11]. As a result, AVLIC reiterates in this intervention to the CRTC our recommendations for reconsideration. We respect the work of the Interim Board, but disagree with the dismissal of these important points.

 

The Interim VRS Board of Director’s recommendation[12] which outlines the sign language interpreters be given “invitee” status is not supported by AVLIC. We assert there must be a change of this status to “Director”. We understand that the thought by the Interim Board was that by having representatives of the interpreting community hold voting privileges presented a possible (real or perceived) conflict of interest. That is, interpreters would directly benefit financially - through employment as VRS interpreters/operators - from the decisions made by the VRS Administrator Board. We respectfully disagree with this assertion.

 

While we concede working interpreters will benefit from VRS in Canada through employment opportunities, it is erroneous to suggest that the two (2) representatives of a key service provider group could not hold a vote without putting themselves in a conflict of interest. All individuals on the Permanent VRS Administrator Board have a vested interest in VRS and, therefore, all should be equally accounted for with voting authority.

 

AVLIC understands the Interim Board believes requiring an interpreting representative be an AVLIC member eliminates the option for open competition[13]. We also understand the Interim Board believes that, if in the future there are subsequent interpreting associations, requiring the representative to be from AVLIC is limiting. However, AVLIC’s concern is that under the current proposal qualifications for selection of members and Board of Directors[14], there is a possibility that interpreting agencies and/or lobby groups could meet the minimum qualifications. Agencies or lobby groups, however, may not necessarily represent the best interests of sign language interpreters. It is this possible misrepresentation that AVLIC is concerned about.

 

Further to the idea of having a comprehensive list of experts designated to positions on the Administrator’s Board of Directors, the Commission may wish to require a representative of the Interpreter Education Programs (IEPs) in Canada be included in the Board composition. This would ensure discussions on the education of future interpreters could be advised on by an expert in interpreting education. Consulting with IEPs, through this representative, would keep the VRS Board apprised of training capacities. First hand knowledge of these capacities would support the goal of increasing the availability of qualified sign language interpreters, who have received training through an IEP, to alleviate the current interpreter shortage.

 

To the same extent, AVLIC fully supports the recommendations put forward by the Interim VRS Board of Directors to mandate positions by all of the consumer stakeholder groups – including three (3) Directors representing Deaf and hard of hearing people.

 

We again thank the Commission for the continuing commitment to providing VRS in Canada and look forward to our ongoing involvement in the implementation.

 

Respectfully submitted,

 

 

Christie Reaume

AVLIC Past President, (formerly President from 2010 – 2014)

 

cc:       Alberta Video Relay Service Committee

British Columbia Video Relay Service Committee

Canadian Association of the Deaf President, Frank Folino

Canadian Association of the Deaf Past President, Doug Momotiuk

Canadian Cultural Society of the Deaf President, Vincent Chauvet

Ontario Video Relay Service Committee

AVLIC Affiliate Chapter Presidents:

ASLIA (Alberta) – Debra Flaig

AVLI-NB (New Brunswick) – Ginnie Black

MAPSLI (Nova Scotia) – Brenna D’Arcy

MAVLI (Manitoba) – Mandy MacDonald

NAVLI (Newfoundland & Labrador) – Shelia Keats

OASLI (Ontario) – Jennifer Best

SLINC (Ottawa) – Roxanne Whiting

WAVLI (British Columbia) – Caroline Tetreault

Canadian Interpreter Education Program Coordinators:

Douglas College – Cheryl Palmer

George Brown College – Phyllis Beaton-Vazquez

Lakeland College – Jody Morrison

Nova Scotia Community College - Denise Smith

Red River College – Rick Zimmer

Université du Québec à Montréal - Anne-Marie Parisot

University of Manitoba – Terry Janzen

 



[4] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc and 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_FRE.doc

[5] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc paragraph 2

[7] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc and 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_FRE.doc

[11] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc paragraph 19

[12] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc paragraph 2

[13] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc paragraph 21

[14] https://services.crtc.gc.ca/pub/DocWebBroker/OpenDocument.aspx?Key=75752... 2014-07-25 VRS Administrator – TNC2014-188 – Proposal_ENG.doc paragraph 36