ARCHIVED - Telecom Commission Letter - 8665-C90-200707060

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Ref: 8665-C90-200707060

Ottawa, 28 July 2006


David Elder
Vice President Regulatory Law
Bell Canada
110 O'Connor Street
7 th Floor
Ottawa , Ontario
K1P 1H1

Dear Mr. Elder:

This is further to an exchange of correspondence between Mr. Bill Abbott, of Bell Canada and Gerry Lylyk, Commission staff, concerning the Commission's direction in Access to pay telephone service, Telecom Decision CRTC 2004-47, 15 July 2004 (Decision 2004-47) to implement a teletypewriter (TTY) upgrade program for certain pay telephones.   Bell Canada indicated that it and other ILECs intended to upgrade the public pay telephone locations subject to Decision 2004-47 with new TTY technology that uses the existing telephone keypad (new TTY keypad technology) in lieu of existing TTY units.

Based on information received by Commission staff from Bell Canada and other stakeholders, it is uncertain whether the new keypad TTY technology could be considered a suitable substitute for existing TTY units in pay telephones.   Staff notes that the Commission recognized in paragraph 149 of Decision 2004-47 that newer technologies may become commercially available that are superior to TTY technology.   In such circumstances, Bell Canada was encouraged by the Commission to apply for a modification of Decision 2004-47 such that the more advanced technology could be installed.

In light of the above, staff is of the view that if Bell Canada wishes to implement a new and/or different TTY technology to meet the TTY upgrade program requirements in Decision 2004-47, it must file an application to do so.

Finally, staff notes that Bell Canada received Commission approval for the recovery of certain costs associated with upgrading pay telephones with TTY units through annual draw downs of approximately $4.5 million from its deferral account.   Staff is of the view that should the Commission approve the substitution of existing TTY units by new TTY keypad technology, the draw downs from Bell Canada will need to be adjusted to reflect the change in incremental costs of installing new TTY keypad technology instead of existing TTY units.

Yours sincerely,

Fiona Gilfillan
Associate Executive Director (acting), Telecommunications

cc.   Jim Roots, Canadian Association of the Deaf
        Roger St.-Louis, l'Association ontarienne des Sourd(e)s francophones

Date Modified: 2006-07-28
Date modified: