When a major telecommunications outage left more than 12 million users without wireless service in July 2022, the disruption was far more dire for the many Canadians dependent on accessibility apps.

That day, Rogers Communications Inc. customers spent hours unable to use their mobile devices for calling, texting or browsing the web unless they were able to find a Wi-Fi connection.

But for those like Kimberly Wood, who is Deaf, it meant any form of communication was practically impossible.

That included finding out about the outage at all.

As Canada害羞草研究所檚 telecommunications regulator seeks to improve transparency and reporting requirements surrounding major network outages, members of the Deaf, hard of hearing and deaf-blind community are urging the Canadian Radio-television and Telecommunications Commission to take their needs into account so that situation doesn害羞草研究所檛 repeat.

害羞草研究所淭here are certain services that if disrupted would affect everyone 害羞草研究所� both hearing and Deaf. For example, an outage affecting landline or mobile services would affect everyone,害羞草研究所� said Wood, founder and chair of the Canada Deaf Grassroots Movement, by email.

害羞草研究所淥n the other hand, there are certain services specifically designed to facilitate communication between Deaf and hearing consumers, such as Video Relay Service, Message Relay Service and text with 911.害羞草研究所�

Those specialized apps are reliant not only on cellular service, but proper preparation by the users themselves.

For example, a hearing customer may be able to borrow someone else害羞草研究所檚 phone with a different carrier during an outage, said Wood. But for Deaf consumers, communicating by phone in such situations would only be possible if someone they know has already downloaded an accessibility program to their device.

Wood said text service through 911 also requires pre-registration with a telecom害羞草研究所檚 technical support, which usually takes about two business days to complete.

害羞草研究所淚mmediate access to 911 on someone else害羞草研究所檚 mobile phone would not be possible during an outage,害羞草研究所� she said.

In March, the CRTC launched a consultation with the goal of developing a framework to improve the reliability and resiliency of telecommunications networks.

Noting that service outages caused by extreme weather, cyberattacks and accidents have been on the rise, the regulator invited comments on a proposal requiring Canadian mobile carriers to notify the CRTC, federal government and other relevant authorities when they experience outages. The approach would also force telecom companies to submit a post-outage report to the commission.

Tackling the issue through a disability lens could help the regulator ensure those with hearing loss aren害羞草研究所檛 put in danger when outages happen, according to Wood.

Her organization害羞草研究所檚 submission to CRTC害羞草研究所檚 consultation stressed that in any outage, 害羞草研究所淒eaf, Hard of Hearing, and Deaf-Blind are most vulnerable when they are unable to communicate with anyone. This can be compounded by a state of emergency where life is at risk.害羞草研究所�

害羞草研究所淲hile it can be disconcerting for hearing people to be cut off during an outage, they are still able to gather information through unfettered verbal interactions from various sources including the radio,害羞草研究所� Wood wrote.

害羞草研究所淭his option is not normally available to those with hearing loss. As a result of this disparity, the DHHDB community experiences more distress than normal during an outage.害羞草研究所�

The group urged the commission to establish a website to provide information about major service outages across the country, which would include video access in both American Sign Language and Quebec Sign Language. It recommended the website害羞草研究所檚 written component, as well as post-incident reporting, be done in plain language 害羞草研究所� defined by meeting a Grade 3 level of comprehension.

Wood said this would allow Deaf consumers to be aware of the type, nature and expected duration of an outage so they can make alternative arrangements to place and receive phone calls, including reaching 911 in an emergency.

害羞草研究所淭his 害羞草研究所榦ne-stop害羞草研究所� place would keep all Deaf consumers apprised of any outages,害羞草研究所� she wrote. 害羞草研究所淭his one stop website would prevent miscommunication or misrepresentation amongst Deaf consumers regarding the nature, severity and duration of such outages.害羞草研究所�

The consultation, which closed for feedback submissions via sign language earlier this month, remains ongoing as the CRTC reviews the comments it害羞草研究所檚 received. Asked about the calls to increase accessibility, the regulator declined to comment on any interventions submitted or potential actions.

During the 2022 Rogers outage, Wood noted how people flocked to popular Wi-Fi hot spots such as caf茅s, fast-food restaurants and public libraries to connect to the internet.

While hearing consumers may have been able to connect to send a quick text, Deaf consumers害羞草研究所� use of specialized services and popular video conferencing apps require lots of bandwidth 害羞草研究所� something Wood said was adversely affected by a crowd of people also using the same hot spot.

She added that public service announcements were not made available in sign language formats and some Deaf people missed critical information shared throughout the day.

In a statement, the Canadian Telecommunications Association said it values input from organizations representing persons with disabilities, including through the CRTC害羞草研究所檚 consultation.

Spokesman Nick Kyonka said the association and the carriers it represents 害羞草研究所渉ave worked alongside various organizations on joint initiatives to help identify barriers to accessibility and better address the needs of persons with disabilities.害羞草研究所�

害羞草研究所淎s an industry, we are committed to communicating effectively with all Canadians and will follow the regulations determined by the commission,害羞草研究所� he said.

Meanwhile, a separate submission to the CRTC from the Deaf and Hard of Hearing Coalition 害羞草研究所� a group formed by Deafness Advocacy Association Nova Scotia, Newfoundland and Labrador Association of the Deaf and Ontario Association of the Deaf 害羞草研究所� raised concerns surrounding the willingness of most big telecoms to act on the issue.

害羞草研究所淕enerally speaking and with the notable exception of Telus, the carriers害羞草研究所� interventions made passing comments at best when it came to notifying and reporting on major service outage mainly or directly affecting (Deaf and hard of hearing) consumers,害羞草研究所� the filing stated.

Both Wood害羞草研究所檚 group and the coalition said they were unaware of any progress by telecoms to rectify the issues they raised.

害羞草研究所�(We) fear that these gaps would persist if a similar outage were to occur tomorrow,害羞草研究所� said Wood.