ARCHIVED - Letter

Ottawa, 10 November 2011

Teresa Griffin-Muir
Vice President, Regulatory Affairs
MTS Allstream Inc.
445 O’Connor Street
Suite 1400
Ottawa, ON K1P 1A4

By email: Teresa.griffin-muir@mtsallstream.com
iworkstation@mtsallstream.com

Re: MTS Allstream Inc. (MTS) updated annual deferral account report on accessibility initiatives (annual report) dated 29 July 2011

Dear Ms. Griffin-Muir:

This letter is a follow-up to the MTS Allstream Inc. (MTS) updated annual deferral account report on accessibility initiatives (annual report) dated 29 July 2011, filed further to Decision 2008-1[1].

Following a review of the above-mentioned report, Commission staff is seeking further clarification and rationale for MTS’s proposed future allocation of the funds to ensure transparency and a common understanding going forward and that funds are used in the best manner possible to improve access to telecommunication services for persons with disabilities. 

Four initiatives have been identified for the outstanding deferral account funds that are earmarked for accessibility initiatives, and in this letter, I am writing with respect to the following three initiatives:

• Text Messaging to 9-1-1 Service
• Voicemail Enhancements
• Website Portal Development

In addition, I have a set of questions with respect to the nature of consultations that were undertaken that informed MTS’ decision making process with respect to which initiatives to support.

Please note that, further to paragraph 23 of Decision 2008-1, the annual report, which contains details for all of the proposed initiatives and the responses to the questions found within this letter, will, taken together, be treated as an application, for Commission approval, of MTS’s “future accessibility proposals”.

Responses to the questions should therefore be submitted no later than 05 January 2012.

TEXT MESSAGING TO 9-1-1 SERVICE:

In Report 2 of the annual report, this initiative is described in the following manner:

The initiative will provide the Deaf, Hard of Hearing, and Speech Impaired (DHHSI) community with a wireless SMS Text messaging service directly to the PSAP when emergency help is required and will meet the reasonable expectations of customers for functionality, quality and reliability.

Decision 2010-224[2] is cited as the rationale for the initiative.  In that Decision, the Commission approved the recommendations in the consensus report entitled Text Messaging to 9-1-1 (T9-1-1) Service (21 January 2010) (ESRE0051).  The Commission also requested that the CRTC Interconnection Steering Committee (CISC) Emergency Services Working Group (ESWG), among other things, begin a technical trial of the solution recommended in ESRE0051and reference is made to further process, if deemed necessary, based on the outcomes of the technical trial.

In Report 2, the following is stated vis-à-vis the actual activities related to the initiative:

MTS Allstream is currently working with the ESWG on developing a national database, and has been asked to test all handsets in Manitoba.

Question 1:        Please position this initiative in the context of the work already undertaken by the CISC ESWG.

Question 2:        Further to Decision 2006-9[3], please verify that none of the monies will be used to fund MTS’s work with ESWG to develop a national database.

Question 3:        For what will the allocated monies be used?  Please describe what will be involved in the testing (i.e. a description of the activities to be undertaken) and how many and the types of handsets that are anticipated to be tested.

Question 4:        As the outcome of the work undertaken by the CISC ESWG will be a final report which may trigger further process, and as this initiative is linked to the work of the CISC ESWG, please clarify whether the outcome of this specific initiative will be the provision to the “(DHHSI) community [of] a wireless SMS Text messaging service directly to the PSAP when emergency help is required” and provide the timelines for the key elements for this initiative.

VOICEMAIL ENHANCEMENTS:

In Table 1 and Report 3 of the annual report, this initiative is described as follows:

Assess the viability of enhancing voicemail features to include accessibility options.

In the body of the annual report, it is stated that:

MTS Allstream is currently in the process of making an assessment on which voicemail enhancement products would be the most beneficial to assist the Deaf, Deafened and hard of hearing community. MTS Allstream has a new voicemail platform that will enable it to launch new products in the future. Therefore, MTS Allstream is undertaking an analysis to determine which products will best serve this community.

Question 5:        Please clarify that the objective of this initiative is not to assess whether or not accessibility options should be included in the voicemail system, but to assess which accessibility options should be included.

Question 6:        Please indicate against what standard or on what basis the assessment will be made and the extent of the consultation with the deaf, deafened and hard of hearing community and related accessibility organizations that will be part of the assessment.

Question 7:        Has a third party been hired to conduct the assessment or is the assessment being conducted internally? If a third party is engaged, what efforts are being made to ensure internal capacity building in this regard is occurring?

Question 8:        As described, this initiative is an assessment.  What is the plan to implement the findings of the assessment and when can consumers expect to have accessibility options available to them?

Question 9:        Please provide more specific details as to the timeframes for this initiative.  This should include, but not necessarily be limited to, the start date, key milestones and deliverables, and the date of completion.

WEBSITE PORTAL DEVELOPMENT:

In Report 4 of the annual report, this initiative is described as follows:

Foundational work will be undertaken on the following Websites to improve the accessibility of functions that are used across multiple pages:

• mts.ca
• mtsallstream.com

The overall goal is to improve the usability, content, navigation, and design.

Commission staff notes that in the MTS 30 March 2010 annual deferral account report on accessibility initiatives, it was reported that the Website Accessibility initiative, which was approved by the Commission in Decision 2008-1, was completed in December of 2009 and the total drawdown from the deferral account for this initiative was $462,000.

Question 10:      Please explain in detail the differences between this initiative ($350,000) and the Website Accessibility initiative ($462,000) so that the Commission and the public can be assured that this initiative represents the most effective use of the deferral account monies.  Your response should include, but not be limited to:

• a detailed accounting of the work accomplished by the Website Accessibility initiative, which should include an explanation of what is meant by “better align with the W3C Web Content Accessibility Guidelines (WCAG) 2.0”[4]  and of the standards, forms and applications that are being referred to by “[i]ncorporation of accessibility standards in some website forms and applications to improve accessibility”[5];
• a detailed accounting of the proposed work;
• a copy of the report(s)/documentation resulting from the “... [initial] testing of the sites to ensure that the changes are effective in improving the accessibility of the website, as well as development of on-going testing methods to ensure future developments are also effective” [6] (Website Accessibility initiative), as well as any gap analysis/audits that were used in the decision making process that resulted in the submission of this initiative; and
• a clear rationalization vis-à-vis the use of deferral account monies to make a corporate website accessible (www.mtsallstream.com), in light of the importance the Commission has placed on “persons with disabilities [having] access to information on disability-specific products and services as well as general information that would improve access to telecommunications and broadcasting services and products available to all customers”[7]  and when there is clear evidence that consumer oriented services to the disabled community still require improvement.

Question 11:      Understanding that there are cost savings associated with linking the work for this initiative with other web development work, Commission staff requires a more precise timeline for the work other than “latter half of 2012”.  Specifically, provide start and completion dates, as well as key milestones and deliverables.

Question 12:      What mechanisms are in place that:

• ensures that the work accomplished through initiatives like Website Accessibility and Web Portal Development are not undone by future web development; and
• staff training/expertise is maintained to ensure the availability of internal capacity to ensure continuity.

NATURE OF CONSULTATIONS WITH ACCESSIBILITY GROUPS:

For each of the four initiatives, MTS Accessibility Forum meetings, which are reported to have been established in May 2010, are referenced.

Question 13:      Please provide a detailed accounting of these MTS Accessibility Forum meetings.  Your response should include, but not be limited to:

• the dates of these meetings;
• the duration of those meetings;
• who participated in these meetings;
• what reports were generated from these meetings;
• what follow-up, if any, resulted in these meetings;
• how these consultations informed MTS’ choice of proposed initiatives
• how each initiative will improve access to telecommunications services for persons with disabilities as identified through these consultations

Commission staff notes that, this past summer, the Commission released the OCAD University report entitled Mobile Wireless Handset Accessibility Assessment, related to Regulatory Policy 2009-430[8]. This report was commissioned by the CRTC and identifies a number of gaps in mobile wireless handset accessibility. In its internal discussions with respect to the best use of the abovementioned funds, MTS may wish to consider this report’s conclusions.

As set out in the Commission staff letter dated 3 February 2011, the Commission may consider directing allocation of these funds to promote the accessibility of telecommunication services if it is not satisfied that they will be utilized in an effective and timely manner.

Sincerely,

ORIGINAL SIGNE BY /

Martine Vallee
Director, Social & Consumer Policy
Policy Development & Research

[1] 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

[2] Telecom Decision CRTC 2010-224, CRTC Interconnection Steering Committee – Improving access to emergency services for people with hearing and speech disabilities

[3] “In light of the foregoing, the Commission determines that draw-downs from each ILEC's deferral account must be applied within its own territory.” (Telecom Decision 2006-9, Disposition of funds in the deferral accounts, paragraph 50)

[4] Paragraph 5, MTS Allstream 31 March 2010 annual deferral account report on accessibility initiatives

[5] Paragraph 5, MTS Allstream 31 March 2010 annual deferral account report on accessibility initiatives

[6] Commission File No. 8638-C12-200602708, Follow-up to Telecom Decision CRTC 2006-9, Disposition of funds in the deferral accounts -  Proposals to expand broadband to rural and remote communities and to improve accessibility to telecommunications services for persons with disabilities, paragraph 31

[7] Paragraph 52, Broadcasting and Telecom Regulatory Policy CRTC 2009-430, Accessibility of telecommunications and broadcasting services the Commission

[8] Broadcasting and Telecom Regulatory Policy CRTC 2009-430, Accessibility of telecommunications and broadcasting services the Commission

Date modified:

2011-11-10