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Ottawa, 31 August 2010

File No.  8678-B2-201010610

Mr. Bill Abbott
Senior Counsel – Regulatory Law
Bell Canada
Floor 19
160 Elgin Street
Ottawa, Ontario K2P 2C4

By email:

Re:  Telecom Decision CRTC 2008-1, Use of deferral account funds to improve access to telecommunications services for persons with disabilities and to expand broadband services to rural and remote communities – Request by Bell Canada to amend Video Relay Service Proposal to include a feasibility study

Dear Mr. Abbott:

This letter is in response to your letter of 23 June 2010 to Commission staff, wherein Bell Canada (the Company) requested confirmation that an independent and impartial Video Relay Service (VRS) feasibility study can be included as part of the VRS initiative originally filed by the Company on 1 September 2006 and approved by the Commission in Use of deferral account funds to improve access to telecommunications services for persons with disabilities and to expand broadband services to rural and remote communities, Telecom Decision CRTC 2008-1, 17 January 2008 (Telecom Decision 2008-1).


In Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430, 21 July 2009 (RP 2009-430), the Commission noted at that time that the record of that proceeding was insufficient to determine whether telecommunication service providers (TSPs) should be required to provide VRS. The Commission concluded that further investigation is necessary to acquire accurate information pertaining to cost, user market size and projected use of VRS and stated its intention to assess whether a follow-up proceeding on VRS is warranted.[1] In order to ensure accurate information is acquired, the Commission emphasized that it considers information resulting from the Video Relay initiatives (trials) of Bell Canada and TELUS Communications Company approved in Telecom Decision 2008-1 as vital to determining whether such a follow-up proceeding is warranted. As a result, Bell Canada and TELUS Communications Company are to implement the initiatives by the date set out in that Decision (31 December 2011).

At Issue

In its letter of 23 June 2010, Bell Canada set out its proposal for a VRS feasibility study to “provide important information on the implementation of VRS nationally that, in the Company’s opinion, cannot be obtained from technical or market trials”.  It explained that such information is “essential to the Commission’s ability to make an informed determination on whether to implement VRS in Canada, and, if so, the most efficient framework for implementing and operating VRS on a national basis”. 

Commission staff requested clarification on certain elements of Bell Canada’s proposed feasibility study, as well as the views of various stakeholders, via interrogatories dated 15 July 2010.  Bell Canada’s response of 29 July 2010 explained that the intention of the feasibility study is to provide detailed data and analysis about VRS requested by the Commission in RP 2009-430 and assist the Company in the development of its VRS trial.  Bell Canada confirmed its intention to proceed with the VRS trial within the timeframe established in Telecom Decision 2008-1 unless otherwise directed by the Commission.

Bell Canada also clarified that the feasibility study and a subsequent trial will not require funding beyond what has already been approved for Bell Canada's VRS initiative in Telecom Decision 2008-1.  Bell Canada noted in its letter of 29 July 2010 that “if, after reviewing the results of the VRS feasibility study the Commission determined that a VRS trial by Bell Canada was unnecessary, the Company would propose other accessibility-related uses for the funds currently allocated for trial activities in the approved VRS initiative.”

Views of Stakeholders

In its letter of 23 June 2010, Bell Canada explained that to ensure that its study is impartial, it consulted with the following stakeholders in the development of its feasibility study proposal and will continue to engage these parties throughout the process: Canadian Association of the Deaf (CAD), the Canadian Hearing Society (CHS), The Canadian Cultural Society of the Deaf (CCSD), the Ontario Association of the Deaf (OAD) and the Centre québécois de la déficience auditive (CQDA) (the consulted stakeholders). 

Commission staff solicited the views of the consulted stakeholders via interrogatories dated 15 July 2010, concerning the steps required to ensure that a feasibility study of VRS in Canada would result in impartial and objective data and their opinion on the level of end-user consultation that would be required to ensure an effective feasibility study.

The consulted stakeholders who responded to the Commission were supportive of Bell Canada’s plan for a VRS feasibility study and are satisfied that their role in the process is an appropriate means of ensuring effective, impartial and objective results.   One party, CQDA, emphasized the importance of ensuring that users of American Sign Language (ASL) and Langue des signes québécoise (LSQ), as well as professional interpreters for each, both inside and outside of Quebec are involved in the consultation process.


Given the assurances provided by the Company noted above, namely that the proposed feasibility study is intended to support the objective set out in RP 2009-430 of gathering precise and useful data on use, costs and rates of operating VRS in Canada and that stakeholder consultation is a critical element of the project at all stages, the Commission considers Bell Canada’s proposal to be acceptable and therefore approves its request to proceed with a feasibility study of VRS, to be funded through a portion of the dollars that have been allocated in the Company’s deferral account for its VRS trial with the remainder currently earmarked for the VRS trial itself.  In doing so, the Commission expects Bell Canada to ensure that it takes into account the circumstances of both Anglophone and Francophone users and interpreters inside and outside of Quebec.



Robert A. Morin
Secretary General

cc: distribution list

Distribution list: Bell:, CAD --; CHS --;  Canadian Cultural Society of the Deaf (CCSD) –;  Ontario Association of the Deaf (OAD) –;  Centre québécois de la déficience auditive (CQDA) -- 

[1] In RP 2009-430, the Commission stated it would assess whether a follow-up proceeding on VRS is warranted three years from the date of that Regulatory Policy, which was issued 21 July 2009.

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