ARCHIVED - Letter
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Ottawa, 25 June 2010
File No. 8665-C12-200807943
By email
Interested Parties to Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430
Re: Implementation of Internet Protocol (IP) Relay Services – CRTC determination on TELUS’s Request for Extension
Dear Madams and Sirs:
Background
In Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430 (RP 2009-430), 21 July 2009, the Commission ordered that all local exchange carriers (LECs), including wireless competitive local exchange carriers (CLECs), and voice over IP (VoIP) providers that are required to provide Teletypewriter (TTY) Relay to provide Internet Protocol (IP) Relay service by 21 July 2010. The Commission allowed parties to satisfy the obligation to provide IP Relay by providing the service directly or by outsourcing the provision of the service to a third-party.
On 5 March 2010, Bell Canada and Bell Aliant Regional Communications, Limited Partnership (Bell Aliant) requested a two-month extension, until 21 September 2010, for their IP Relay implementation, which the Commission approved in a letter dated 30 March 2010.
In a letter dated 21 April 2010, Télébec, Société en commandite, NorthernTel, Limited Partnership and KMTS submitted that their IP Relay offering would be dependent on Bell’s and requested the same extension as Bell.
At Issue
On 3 May 2010, TELUS Communications Company Inc. (TELUS) filed a letter with the Commission in which it noted the recent and significant demand for its wholesale IP Relay services. TELUS submitted that the wholesale demand was impacting the timelines for the development and launch of both its retail and wholesale IP Relay offerings; as a result, TELUS requested that the Commission grant the following extensions to enable the Company to launch high quality and robust IP Relay services:
- a two-month extension to September 21, 2010, for the delivery of its IP Relay services for its retail customers; and,
- an extension until December 31, 2010 for TELUS to implement IP Relay services on behalf of each of its wholesale IP Relay customers (10 LECs[1]).
TELUS submitted that without such an extension, TELUS would not be able to commit to the delivery of wholesale IP Relay services to its wholesale customers, forcing these TSPs to examine alternative methods of IP Relay services delivery, including self-supply or the use of third party providers. As a result, TELUS did not know when these TSPs would be able to deliver IP Relay services under alternative arrangements.
Positions of Parties
The Commission solicited comments on this issue from all parties to RP 2009-430 in a letter dated 11 May 2010:
- Two groups representing the interests of persons with hearing disabilities commented – the Canadian Association of the Deaf (CAD) and the Canadian Hard of Hearing Association-Hamilton (CHHAH). CAD submitted that it did not support TELUS’s request due to TELUS’s approach to consultation with them. CHHAH supported CAD’s comments.
- All LECs that commented[2] supported TELUS’s request. SaskTel, MTS Allstream, Rogers, and Vidéotron identified themselves as customers of TELUS’s wholesale IP Relay services. These LECs further submitted that their ability to meet their own IP Relay retail deadlines were dependent on TELUS’s ability to provide them with access to TELUS’s wholesale IP Relay service.
- EastLink and Rogers requested that the CRTC extend the IP Relay implementation deadline for 31 December 2010 for all LECs.
In reply, TELUS stated that “All of the TSPs have supported TELUS’ request for an extension for the delivery of IP Relay services, with many explicitly agreeing that a short delay for a delivery of robust IP Relay services was far more preferable than rushing the services to market to meet the Commission’s July 21, 2010 deadline. It is evident that all TSPs, including TELUS, view IP Relay services as an important service enhancement for Deaf and hard of hearing customers, and that the services require suitable time for development.”
TELUS responded to CAD’s comments by noting that TELUS has since engaged CAD in discussions, invited CAD to video relay town hall sessions and “commits to keep the CAD, as well as other local groups, informed and up-to-date on the Company’s progress.”
Analysis and conclusions
The Commission considers it important that high quality relay services be made available to Canadians as quickly as possible. The Commission considers that TELUS and its wholesale customers and other LECs have demonstrated that they are working to ensure a robust, high quality IP Relay service will be available to their retail customers as quickly as possible; however, it will not be possible for many LECs to meet the 21 July 2010 IP Relay implementation deadline set in 2009-430 for reasons of wholesale service availability beyond their control.
Given the circumstances of this case, the Commission
- Approves TELUS’s request to extend its retail IP Relay implementation deadline to 21 September 2010.
- Approves EastLink’s and Roger’s request to extend the retail IP Relay implementation deadline of all LECs to 31 December 2010 (including those of TELUS’s wholesale customers).[3]
- Expects all LECs to provide access to high quality IP Relay services as quickly as possible – noting that, as a result of TELUS’s staggered wholesale IP Relay launch approach, several of its wholesale customers will have access to its IP Relay services as early as October 2010.
- Requires all LECs to report to the Commission via letter once they are providing access to IP Relay services to their retail customers. These letters are to be submitted to the Commission no later than 31 December 2010.
- Also expects LECs to notify their customers of the availability of their retail IP Relay services, once these are launched.
- Requires TELUS to update the Commission on the progress of its retail and wholesale IP Relay service offerings via status reports, to be filed every 30 days, beginning 31 July 2010 until 31 December 2010. The first report should contain an itemized list of activities leading to full implementation.
- The Commission also requires all LECs that are not using TELUS as their underlying IP Relay provider to update the Commission on the status of their respective retail and/or wholesale IP Relay service offerings via status reports, to be filed every 30 days, beginning 31 July 2010 until 31 December 2010. The first report should contain an itemized list of activities leading to full implementation.
- Requires all incumbent local exchange carriers (ILECs) who filed proposed tariffs for their IP Relay service, to file proposed tariff amendments reflecting the revised effective date of the service no later than 30 days before the proposed effective date.
- Directs all large and small ILECs who have not yet filed tariffs for IP Relay service, to file proposed tariffs no later than 30 days before the proposed effective date of the service.
With respect to concerns raised about TELUS’s approach to consultation, the Commission considers TELUS’s response to ensuring future engagement to be appropriate at this time.
Sincerely,
[ORIGINAL SIGNED BY
John Keogh
on behalf of ]
Robert A. Morin
Secretary General
Cc: distribution list
Distribution list:
Bell.regulatory@bell.ca ; regulatory.affairs@telus.com ; regulatoryaffairs@nwtel.ca ; reglementa@telebec.com ; document.control@sasktel.sk.ca ; iworkstation@mtsallstream.com ; regulatory@bell.aliant.ca ; mworkman@blindcanadians.ca ; p_gordon@rogers.com ; Jroots@cad.ca ; mpotvin@ccbnational.net ; arendall@cogeco.net ; gmalkowski@chs.ca ; jbentley@chs.ca ; dfels@ryerson.ca ; judo@ryerson.ca ; cqda@videotron.ca ; tjgreen@bellnet.ca ; cathy.moore@cnib.ca ; ccd@ccdonline.ca ; bxt1@nbrscanada.com ; info@raaq.qc.ca ; gkane@stikeman.com ; hardy63@live.com ; andres@isptelecom.net ; regaffairs@quebecor.com ; gcordeau@maskatel.qc.ca ; regulatory.matters@corp.eastlink.ca ; brenda.stevens@rci.rogers.com ; regulatory@telnetcommunications.com ; s.cloutier@axion.ca ; regulatory@sjrb.ca ; regulatory.aff@fidomobile.ca ; michel.messier@cogeco.com ; regulatory@vianet.ca ; sbishay@iristel.com ; ataylor@personainc.ca ; info@mountaincable.net ; lcundy@telus.net ; documents@accesscomm.ca ; jboutros@globility.ca ; regulatory@bell.aliant.ca
[1] TELUS provided the list of its potential wholesale IP Relay customers to the Commission in confidence.
[2] Bell Canada and Bell Aliant, SaskTel, MTS Allstream Inc., Bragg Communications Inc., operating as EastLink, Quebecor Media Inc. au nom de Vidéotron ltée, Cogeco Cable Inc., Rogers Communications Inc.
[3] For additional clarification, the Commission notes that this deadline, i.e. 31 December 2010, is the same for the implementation of IP Relay services whether these are provided in English or French.
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