ARCHIVED -  Telecom Decision CRTC 87-4

Telecom Decision

Ottawa, 20 May 1987

Telecom Decision CRTC 87-4

BRITISH COLUMBIA TELEPHONE COMPANY - 50% DISCOUNT FOR INTRA-COMPANY MESSAGE TOLL SERVICE RATES FOR HEARING OR SPEECH-IMPAIRED SUBSCRIBERS

I BACKGROUND

On 30 October 1981, the Commission received an application from British Columbia Telephone Company (B.C. Tel), under Tariff Notice 360, for approval of tariff revisions providing for the introduction of a 50% discount on customer-dialed intra-company (including the telephone system of the City of Prince Rupert) long distance telephone calls placed by a certified hearing or speech-impaired residence service subscriber using a Telecommunications Device for the Deaf (TDD).

In Telecom Order CRTC 81-558, dated 24 November 1981, the Commission granted the application interim approval, pending consideration by the Commission of the results of a study then being conducted by Bell Canada (Bell) on the use of Message Toll Service (MTS) by certified disabled TDD users in its territory.

By letter dated 27 February 1984, the Commission furnished B.C. Tel with a copy of Bell's report which recommended the retention of a 50% discount for all intra-Bell customer-dialed long distance calls originated by company-registered certified users of a TDD. The Commission advised that the 50% discount remained in effect in Bell territory. The Commission requested B.C. Tel to comment, by 15 March 1984, on the applicability of Bell's recommendations to B.C. Tel's own situation and to copy its letter of response to interested parties. These parties were invited to file their comments regarding the company's position by 16 April 1984. B.C. Tel was asked to reply to comments by 26 April 1984.

In letters dated 14 March 1984 and 11 April 1984 respectively, B.C. Tel and the Greater Vancouver Association of the Deaf (GVAD) submitted that the results of Bell's study may not be applicable to B.C. Tel. In view of their concerns, the Commission requested the company, on 29 June 1984, to submit a proposal for a study of an appropriate discount rate for customer-dialed intra-company long distance rates for registered TDD users. B.C. Tel was directed to consult fully with GVAD in developing the study.

On 26 June 1985, the Commission approved B.C. Tel's study proposal. On 19 February 1986, B.C. Tel provided the Commission and interested parties with its study results.

The Commission received comments on B.C. Tel's study and recommendations from Nigel David Allen, GVAD and the Western Institute for the Deaf (WID).

II POSITIONS OF PARTIES

B.C. Tel submitted that, according to its study results, the mean durations of TDD calls were from 7.4% to 40.0% greater than those for non-TDD calls. B.C. Tel's study concluded that the 50% discount on MTS charges for registered TDD users provides adequate value of service compensation.

B.C. Tel also submitted that, according to its study results, approximately 52% of long distance calls that originated from the 423 registered TDD telephone numbers did not terminate at registered TDD telephone numbers. It proposed billing and rate changes providing for the application of the 50% discount only to MTS calls that originate from and terminate at telephones of registered TDD users and to MTS calls that originate from these telephones and are processed through the Voice Relay Service Centre (VRSC).

GVAD and WID opposed this proposal to limit the application of the 50% discount. GVAD stated that sometimes non-hearing-impaired people make long distance telephone calls for registered hearing-impaired subscribers from those subscribers' telephones. GVAD stated that these calls may be of greater duration than regular calls because of the need for consultation between the caller and the hearing-impaired subscriber.

WID stated that a large proportion of TDD users are not registered. It submitted that sometimes a registered hearing-impaired TDD user does not know if the TDD user he is calling is registered; therefore, the implementation of B.C. Tel's proposal would restrict and penalize registered hearing-impaired TDD subscribers.

In reply, B.C. Tel stated that the problem of determining the terms for an appropriate discount could be solved if all hearing-impaired TDD users were registered with the company. It therefore proposed to implement a mail campaign, with the cooperation of WID, to encourage hearing-impaired TDD users to register.

Mr. Allen, GVAD and WID argued that the value of service considerations which warranted a 50% discount on MTS charges for intra-company long distance TDD calls should also be applicable to MTS charges for TDD calls made by business and non-hearing-impaired users. Mr. Allen suggested that business subscribers who place or receive TDD calls would have to register a business telephone number as a TDD-only line to qualify for the discount.

GVAD and WID also suggested that the 50% discount for MTS charges should apply to calls from non-hearing-impaired subscribers to TDD users when these calls are processed through the VRSC. They argued that these calls also take an extended time to process.

In reply, B.C. Tel stated that the current 50% discount, and the availability of the services of the VRSC, are adequate in assisting non-hearing-impaired persons to communicate with hearing-impaired persons. It stated that the 1982 Bell study concluded that businesses have a social responsibility to meet the needs of their customers and employees, and that it would be inappropriate for the company and its customers to shoulder social responsibilities which rightly belong with all businesses. B.C. Tel also contended that the fact that hearing-impaired persons' friends, relatives and associates pay regular long distance charges does not deprive hearing-impaired persons of service. It noted that non-hearing-impaired persons benefit from communicating with the hearing-impaired through the VRSC, without having to bear the purchase and maintenance costs of a TDD.

GVAD and WID agreed that a 50% discount should apply to toll calls made by registered hearing-impaired TDD users from locations other than their residence. B.C. Tel noted that such calls placed using B.C. Tel calling cards would be eligible for 50% discounts.

GVAD submitted that the 50% discount should apply to calls routed to points outside of B.C. Tel's operating territory. B.C. Tel replied that this would require discussion with the other members of Telecom Canada; it stated that no such discussions were scheduled at that time.

III CONCLUSIONS

As previously noted, the 50% discount currently applies, without restriction, on direct dialed intra-company long distance telephone calls placed by residence subscribers who are certified to be hearing or speech-impaired and who are registered TDD users.

With regard to the further limitations on the application of the discount proposed by B.C. Tel, the Commission considers that their implementation would be unduly restrictive. The purpose of the discount is to take account of the appreciably longer time that is required for the registered hearing or speech-impaired to send a communication over the telephone network. As the record indicates, even where the hearing or speech-impaired receive the assistance of people who are not so impaired, the calls may be of greater duration because of the time required to permit the consultation necessary for accurate communication.

With regard to situations where registered TDD users call unregistered TDD users, while the Commission considers that TDD users should accept responsibility for registering with the company, the failure of some users to do so has no bearing on the extent to which time is consumed on a long distance call that has been originated by a registered user. The Commission further notes that Bell's 50% discount for MTS rates for registered TDD users is not limited to calls that both originate and terminate at the residence telephone number of a registered TDD user.

However, the Commission considers that the application of the discount should be restricted to calls originated by or on behalf of those who are registered with B.C. Tel. The Commission is of the view that there would be too great a potential for abuse of the discount if it were extended to TDD owners who are not certified as being hearing or speech-impaired and registered with B.C. Tel.

The option of using the VRSC does exist, however, for communications between non-hearing or non-speech-impaired subscribers and those who are hearing or speech-impaired, and the Commission considers that the 50% discount should apply to all calls routed through the VRSC.

With regard to the application of the discount to calls to locations outside B.C. Tel's operating territory, the Commission notes that in Telecom Order CRTC 87-315, dated 14 May 1987, it approved an application by B.C. Tel to apply the existing 50% discount to calls to locations in all other parts of Canada.

In light of the above, the Commission directs B.C. Tel to file under Tariff Notice 360A, by 19 June 1987, tariff revisions for Item 285 of its General Tariff, providing for the application of a 50% discount for intra-company MTS charges to:

a) all long-distance calls originating from and billed to the residence telephone number of
registered certified hearing or speech-impaired TDD users;

b) all long-distance calls employing a registered certified hearing or speech-impaired TDD user's B.C. Tel calling card;
and

c) all long-distance calls routed through the VRSC.

The Commission further directs B.C. Tel, after consulting with GVAD and WID, to develop and implement an information program to advise its subscribers about the 50% discount and about the advantages to hearing or speech-impaired TDD users of registering with B.C. Tel to qualify for it.

Fernand Bélisle

Secretary General