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Telecom Letter Decision
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Ottawa, 8 November 1990
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Telecom Letter Decision CRTC 90-16
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To: - Maritime Telegraph and Telephone Company, Limited
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- The Canadian Association of the Deaf- Society of Deaf and Hard of Hearing Nova ScotiansRe: Maritime Telegraph and Telephone Company, Limited - Revenue Requirement for 1990 and 1991, Deferred Tax Liability -
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On 12 March 1990, the Canadian Association of the Deaf (CAD) filed an application requesting that the Commission require the four Atlantic telephone companies to establish Message Relay Service (MRS) for the deaf by 1 July 1990. On 11 May 1990, the Society of Deaf and Hard of Hearing Nova Scotians (SDHHNS) filed a separate application making the same request with respect to Maritime Telegraph and Telephone Company Limited (MT&T) alone. By separate letters dated 7 June 1990 and 8 June 1990, the Commission advised CAD and SDHHNS, respectively, that it would consider the issues related to the provision of MRS in Nova Scotia in the context of the proceeding announced in Maritime Telegraph and Telephone Company, Limited - Revenue Requirement for 1990 and 1991, Deferred Tax Liability, Telecom Decision CRTC 89-17, 21 December 1989.
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In the revenue requirement proceeding, interrogatories were addressed to MT&T concerning the provision of MRS. At the hearing, held in Halifax from 24 September to 3 October 1990, MT&T and SDHHNS witnesses were examined with respect to the relevant issues and the arguments of both parties were heard.
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MT&T proposed to introduce MRS by 1 November 1991, an implementation date that would allow it to use operators and floor space freed up as a result of its implementation of the Automated Voice Response System (AVRS). The company indicated that it had decided to provide MRS in this timeframe in the interests of minimizing costs and avoiding staff lay-offs. However, MT&T stated that, in any event, it could implement MRS within six months of a Commission decision requiring it to introduce the service.
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SDHHNS argued that to further delay the implementation of MRS until six months after the date of the Commission's decision in the revenue requirement proceeding would constitute an unnecessary and inappropriate delay on top of all the other delays that the hearing-impaired have had to endure. SDHHNS requested, therefore, that the Commission issue a decision with respect to MRS as soon as possible, prior to its decision on MT&T's revenue requirement. SDHHNS indicated that, other than the implementation date, its only concern with respect to MT&T's proposal for the provision of MRS is that the company should appoint a person who would be primarily responsible for the service.
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MT&T indicated that MRS would be offered using dedicated operators and that access would be provided 24 hours a day, seven days a week, through two 1-800 numbers, one for voice calls and one for calls from users of telecommunications devices for the deaf (TDDs). The company proposed that all toll calls originating in Nova Scotia, placed through MRS and terminating in Canada, be eligible for a 50% discount.
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The company indicated that it does not propose at this time to provide bilingual MRS. MT&T stated that it is not aware of any demand from the hearing-impaired community for bilingual service, but that it would consider the need for bilingual service should a demand arise in the future. At the hearing, SDHHNS indicated that there would be a limited number of TDD-users whose primary language is French, and that these users would be found primarily in New Brunswick, not in Nova Scotia.
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In British Columbia Telephone Company - Voice Relay Service Centre, Telecom Decision CRTC 85-29, 23 December 1985 (Decision 85-29), the Commission noted with respect to the provision of MRS in British Columbia that hearing-impaired subscribers pay full rates for primary exchange service and, as well, incur expenses for their own special terminals (the TDDs). The Commission found that the hearing-impaired should therefore be provided with the same ability as any other subscriber to communicate with any and all other subscribers. The Commission is of the view that these findings are equally applicable to MT&T and its subscribers. The Commission concludes therefore that MT&T should implement MRS.
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In the Commission's view, MRS should be provided 24 hours a day, seven days a week, so that the hearing-impaired will have telephone access that closely approximates that of other subscribers. The Commission notes the company's intention to provide service on this basis and directs that it do so.
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MT&T's proposals provide for a 50% discount on toll calls originated in Nova Scotia, routed through MRS and terminating in Canada. The Commission considers this proposal reasonable and directs the company to provide for such a discount.
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The Commission notes that neither MT&T nor SDHHNS are aware of a need for bilingual MRS, and that MT&T intends to consider the provision of bilingual service should there be a demand for it in the future. Accordingly, the Commission does not consider it necessary at this time to require MT&T to make provision for bilingual MRS.
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The Commission also notes SDHHNS's request that MT&T appoint a person who would be primarily responsible for MRS, and encourages MT&T to assign a senior representative to serve as a contact person regarding the provision of MRS.
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SDHHNS requested that MT&T be directed to provide MRS as soon as possible. The company stated that it is capable of providing MRS within six months of the date of being ordered to do so, but suggested that additional expenses would be incurred if it were to introduce MRS prior to 1 November 1991.
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In the opinion of the Commission, the balance between saving money by postponing the implementation of MRS until AVRS is implemented, and the need to provide the hearing-impaired with proper access to the telephone network as soon as possible, weighs in favour of an earlier implementation date. Therefore, the Commission directs MT&T to implement MRS by 8 May 1991, in accordance with its proposals in the revenue requirement proceeding and with this decision. The Commission will take the expenses of providing MRS into account in its forthcoming decision on MT&T's revenue requirement and related matters.
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MT&T is directed to file proposed tariff pages for the provision of MRS no later than 30 days before the implementation of service.
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Allan J. Darling
Secretary General
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c.c.: Atlantic Communication Technical Workers Union
Canadian Business Telecommunications Alliance
Innkeepers Guild of Nova Scotia
Nova Scotia Government Retired Employees Association
Novix Incorporated and Atlantic Paging Services Inc.
Rural Dignity of Canada et al
Tourism Industry Association of Nova Scotia
Unitel Communications Inc.
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