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Ottawa, 19 May 2009
File Nos.: 8740-B2-200906430
BY E- MAIL
Mr. David Palmer
Director – Regulatory Affairs
160 Elgin Street, 19th Floor
Dear Mr. Palmer:
RE: Bell Canada Tariff Notice 7191 and Bell Aliant Tariff Notice 253 – Voice dialing
On 21 April 2009, the Commission received applications by Bell Canada and Bell Aliant Regional Communications, Limited Partnership (the companies), under cover of Tariff Notices 7191 and 253, respectively, in which the companies proposed modifications to their respective General Tariff – Item 2165, Calling Features - Voice dialing, in order to reflect changes to the Voice Dialing feature.
Commission staff notes that in Bell Aliant Regional Communications, Limited Partnership and Bell Canada, Follow-up to Telecom Decision CRTC 2008-1, Use of deferral account funds to improve access to telecommunications service to persons with disabilities and to expand broadband services to rural and remote communities, Report on the Status of Accessibility Initiatives, (Funds document) 31 March 2009, the companies provided the Commission with an updated estimate of the deferral account drawdown required for the implementation of the Voice dialing service. Commission staff advise the companies that this document is being placed on the record of these tariff applications.
Commission staff further notes that the companies provided certain information in the Funds document in confidence to the Commission, pursuant to s. 39 of the Telecommunications Act, but that abridged versions of this submission and Attachment 1 were provided by the company. An abridged version of these documents are available on the Commission's web site
The companies are requested to provide responses to interrogatories as set out in the Attachment by 2 June 2009.
Original signed by C. Bailey (for)
Senior Manager, Tariffs
cc: Joanne Baldassi , CRTC, (819) 997-4576, email@example.com
Canadian Association of the Deaf/Association des Sourds du Canada, firstname.lastname@example.org, email@example.com , firstname.lastname@example.org
Belleville Association of the Deaf, email@example.com, firstname.lastname@example.org
Adaptive Technology Resource Centre, email@example.com
ARCH Disability Law Centre, firstname.lastname@example.org
Council of Canadians with Disabilities, email@example.com
Council of Canadians with Disabilities / Canadian Association of Independent Living Centres, firstname.lastname@example.org
Canadian National Institute for the Blind (CNIB), email@example.com
Canadian Council of the Blind, firstname.lastname@example.org
Ottawa Deaf Centre, email@example.com
Ontario Association of the Deaf, firstname.lastname@example.org
The Canadian Hearing Society, email@example.com
Canadian Association for Community Living, firstname.lastname@example.org
Centre québécois de la déficience auditive, email@example.com
Public Interest Law Centre, firstname.lastname@example.org
Disability and Information Technologies (Dis-IT), email@example.com; firstname.lastname@example.org
Alliance for Equality of Blind Canadians/L'Alliance pour l'égalité des aveugles canadiens, email@example.com
Neil Squire Society, firstname.lastname@example.org
Chris Stark, email@example.com
1) At paragraph 6 of their cover letter dated 21 April 2009, the companies note that customers will be able to enrol up to 100 contacts via the voice enrolment feature on the Voice Activated Dialing (VAD) system, and can expand their contact list to up to 1,000 contacts using an on-line text-based address book.
(a) Given that many of the potential customers for this service may be elderly, address whether any alternative exists to the on-line address book to increase the number of contacts to 1,000.
(b) Given that many of the potential customers for this service may be blind or have vision or mobility impairments, to what extent is the on-line enrolment feature accessible to persons with disabilities?
2) At paragraph 7 of the cover letter, the companies noted that customers who wish to complete long-distance calls using an alternate supplier's network will be required to program the numbers to be dialled by the VAD system as “1010 + Carrier Identification Code + 1 + area code + telephone number. The companies estimated that the costs of developing and implementing the systems and process modifications required to support the customer's pre-subscribed carrier for long-distance calls made through the VAD system would be ####.
(a) Provide a detailed explanation of how long-distance calls are handled today over the existing VAD platform used by residential customers.
(b) If equal access is supported by the existing VAD platform, justify why a dial-around solution should be considered reasonable by the Commission on the new VAD platform.
3) At paragraph 8, the companies stated that customers who do not want to use the VAD system may place a call normally by dialing the number upon hearing regular dial tone during the three seconds prior to the VAD connecting, and that customers can contact the companies if the three second interval is insufficient.
(a) • Provide a detailed explanation of how the companies plan to notify customers regarding the three second interval, and how to obtain a longer interval.
(b) Identify what information will be provided to customers in the customer communications materials developed in conjunction with these tariff filings, as noted in Table 2 of the Funds document.
(c) Given that many of the potential customers for this service may be blind or have vision or mobility impairments, address how the planned notification methods are accessible for persons with these disabilities.
4) At paragraph 10 of the cover letter, the companies noted that customers will be encouraged to manually dial the standard 9-1-1 service before connecting to VAD. Identify whether any testing or consultation has been conducted to ensure that the three second delay will allow sufficient time for mobility/vision-impaired users to manually dial 9-1-1 . If so, provide details. If not, provide justification for the three second delay in this context.
5) In proposed tariff page 205B, the companies state under Item 2165.3 e (1) that “the customer must consent to the fact that callers using the VAD system to access 9-1-1 services must orally provide location and telephone number to the operator answering the call.” At paragraph 10 of the cover letter, the companies indicated that E9-1-1 services access is expected to be available in October.
(a) Provide a detailed explanation of the level of 9-1-1 support that exists today over the existing VAD platform used by residential customers.
(b) If the current VAD service platform supports E9-1-1, justify why customers should be required to wait until October 2009, or some future time, for the VAD service to offer the same E9-1-1 functionality as traditional wireline.
(c) Explain how the companies plan to notify customers regarding the level of 9-1-1 support provided at service launch, and the method by which the companies plan to obtain customer consent (ex. Obtain the customer's written consent, oral consent verified by an independent third party, or consent by the use of a toll-free number).
(d) Given that many of the potential customers for this service may be blind or have vision or mobility impairments, address how the planned notice and consent methods are accessible for persons with these disabilities.
6) Refer to Bell Aliant Regional Communications, Limited Partnership and Bell Canada , Report on the Status of Accessibility Initiatives , 31 March 2009 , Table 2. The companies note that user testing was held on March 2 and 3, 2009 with “general population users and on March 12, 2009 with “senior citizens”, but that user testing with mobility/vision-impaired users was to be held in April 2009.
(a) Identify whether or not user testing has already taken place with mobility/vision impaired users. If so, provide details as to the results of this testing, and identify any service modifications the companies plan to implement to meet the needs of these users, and in what timeframe.
(b) If not, indicate by when the companies intend to test the service feature on mobility/vision-impaired users.
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