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ARCHIVED -  Telecom Order CRTC 96-269

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Telecom Order

Ottawa, 25 March 1996
Telecom Order CRTC 96-269
IN THE MATTER OF the proceeding initiated by Bell Canada - Tariff Revisions Relating to the Recovery of Costs Associated with Maintaining and Improving Relay Service, Telecom Public Notice CRTC 95-43, 22 September 1995 (Public Notice 95-43).
WHEREAS Bell Canada (Bell) filed Tariff Notices 5556 on 21 August 1995, 5556A on 11 September 1995 and 5556B on 1 November 1995, for approval of tariff revisions to allow for the recovery of costs associated with maintaining and improving Relay Service;
WHEREAS Bell proposed that a $0.15 per month charge (which would include a 25% mark-up to recover fixed and common costs) be applied to all residence and business switched access lines as well as to those switched access services provided to independent telephone companies and cellular providers;
WHEREAS, in Public Notice 95-43, the Commission requested comments on the proposal;
WHEREAS comments were received from the Canadian Association of the Deaf (CAD), The Canadian Hearing Society, Canadian Cable Television Association (CCTA), Canadian Wireless Telecommunications Association (CWTA), Centre québécois de la déficience auditive (CQDA), Québec-Téléphone, Association des compagnies de téléphone du Québec inc. (ACTQ), Rogers Cantel Inc. (Cantel), Télébec ltée (Télébec), and Unitel Communications Inc. (Unitel);
WHEREAS the three associations representing the hearing impaired supported the application, contingent on noticeable improvements to Relay Service in four main areas: access, technology, training and feedback;
WHEREAS Bell indicated that it had worked closely with various community groups representing Relay Service users and had identified the need for further improvements to the service, including quicker speed of call answer through technology changes and staffing arrangements, implementation of a customer survey and the establishment of an additional Relay centre in 1995 and possibly another one by the end of 1996;
WHEREAS ACTQ and Québec-Téléphone suggested that the Commission should consider adjusting the proposed tariff to reflect the small volume of users in their customer base;
WHEREAS Bell submitted that the number of registered users identified by ACTQ and Québec-Téléphone as a proportion of their customer base was consistent with that for Bell;
WHEREAS ACTQ, Québec-Téléphone and Télébec requested that a portion of the amount approved by the Commission be retained by them to absorb the administrative costs of the service;
WHEREAS ACTQ indicated that it would prefer to have the Relay surcharge separately identified on customer bills;
WHEREAS CQDA and CAD raised the concern of a backlash or negative reflection upon Relay Service users should the surcharge be separately identified on an on-going basis;
WHEREAS Bell submitted that the cost of providing Relay Service should be borne by the general body of telecommunications users and that, once per annum, the customer's account should include a Subscriber Information Message advising that a portion of their monthly service supported Relay Service, thereby alleviating the concern of CQDA and CAD as well as minimizing the additional administrative expenses of billing and collecting the surcharge referred to by Québec-Téléphone, ACTQ and Télébec;
WHEREAS CWTA stated that in Bell Canada - Review of Revenue Requirements for the Years 1985, 1986 and 1987, Telecom Decision CRTC 86-17, 14 October 1986 (Decision 86-17), the Commission required Bell to fund Relay Service through the general body of telephone subscribers and had rejected a separate levy on a per access line basis;
WHEREAS, in addition, CWTA considered it inappropriate for Bell to apply causal costs related to the provisioning of Relay Service to switched access service provided to cellular carriers, as these costs are not causal to the provision of cellular access service;
WHEREAS Cantel opposed the application, arguing that it was inconsistent with the well-established principles of cost causality upon which cellular access rates have been based;
WHEREAS Cantel indicated that all subscribers to Relay Service are Bell customers - not cellular customers - and that, should Cantel experience demand from its customers for cellular compatible TTY equipment, or for Relay Service, it would consider instituting its own service;
WHEREAS Bell submitted that the telecommunications market in Canada has undergone significant change since Decision 86-17;
WHEREAS Bell stated that the projected volumes and costs of providing Relay Service are significantly higher today and that the proposed tariff is intended to ensure that all suppliers of telecommunications services whose customers might use Relay Service contribute to the cost of providing the service;
WHEREAS Bell indicated that, contrary to Cantel's assertion that all subscribers to Relay Service are Bell customers, in the fall of 1994, an average of 2 calls per week involved cellular users and that in November of 1995, that number had grown to an average of 7 calls per day;
WHEREAS CCTA considered that all issues associated with any proposed mark-up on unbundled, bottleneck facilities and services such as Relay Service should be addressed in the context of the local unbundling proceeding and that the Commission should only approve rates for Relay Service on an interim basis until a decision is rendered in that proceeding;
WHEREAS Unitel opposed the mark-up and stated that the introduction of an incremental 25% mark-up on a new access line charge, applied to the entire subscriber base, would
be tantamount to a general rate increase;
WHEREAS Bell submitted that the fact that Unitel and other suppliers could provide Relay Service to their end-customers (Québec-Téléphone and Cantel indicated that they would consider instituting their own Relay Service) suggests that Relay Service is not a bottleneck service and that CCTA's and Unitel's statements regarding the inclusion of mark-up in the prices for bottleneck services are not relevant;
WHEREAS Unitel questioned the need to establish a fourth Relay Office and was of the view that the Commission should implement a procedure to monitor the revenues and costs associated with Relay Service on an annual basis;
WHEREAS Bell stated that a fourth centre specifically for Relay Service was required to respond to the current demand and the expected growth in demand as a result of an aging population;
WHEREAS Bell indicated that it had specifically selected a multifunctional platform for the provision of Relay Service in order to minimize the ongoing costs of the service;
WHEREAS the Commission has considered the comments and reply comments filed in this proceeding;
WHEREAS the Commission considers the planned improvements to Relay Service necessary in order to meet current user demand and provide appropriate service levels in the future;
WHEREAS the Commission notes that circumstances have changed considerably since the inception of Relay Service in 1986 and that today, telecommunications is an
evolving competitive industry;
WHEREAS the Commission considers that all suppliers of telecommunications services whose customers use Relay Service should contribute to the cost of providing the service;
WHEREAS the estimated cost of providing Relay Service has grown from an initial $2.5 million with a daily call volume of 1500, to $13 million with a daily call volume of 4500;
WHEREAS demand is projected to continue to grow at a rate of 10% per annum for the period 1996-2005;
WHEREAS Bell has indicated that the current level of service cannot be maintained if Relay Service is to continue to be funded from general revenues;
WHEREAS the Commission is of the view that it is in the public interest to ensure that reasonable levels of service quality be maintained and that, to this end, all subscribers should pay to ensure that Relay Service continues to meet the demands placed on it;
WHEREAS the record of this proceeding indicates that cellular subscribers have been using the Relay centres since mid-1994 and the Commission considers that it would be appropriate for cellular providers to fund Relay Service on a per number basis until such time as they offer their own Relay Service;
WHEREAS the Commission considers that a 25% mark-up to recover fixed and common costs would be inappropriate; and
WHEREAS the Commission considers that a surcharge for Relay Service should be added
to the monthly charges for switched network access applicable to all residence and business customers, as well as independent telephone companies and cellular providers -
IT IS HEREBY ORDERED THAT:
1.  Bell is directed to issue approved tariff pages reflecting a $0.13 per month surcharge for Relay Service, to be added to the monthly charges for switched network access applicable to all residence and business customers, as well as independent telephone companies and cellular providers.
2. B ell is directed to notify subscribers, via a one-time billing insert, that a portion of their monthly charges supports Relay Service.
3. T he request of Québec-Téléphone and ACTQ to reduce the surcharge to reflect their customer base is denied.
Allan J. Darling
Secretary General

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