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Ottawa, 25 May 2012

File No.: 8665-C12-200807943

BY EMAIL

Mr. Ted Woodhead
Vice-President
Telecom Policy & Regulatory Affairs
TELUS Communications Company
215 Slater Street
Ottawa ON K1P 0A6

Ted.woodhead@telus.com
Regulatory.affairs@telus.com

Dear Mr. Woodhead:

Re: Regulatory Policy CRTC 2009-430 – Accessibility of Telecommunications and Broadcasting Services

In Broadcasting and Telecom Regulatory Policy CRTC 2009-430, the Commission reviewed its relay services policy framework as part of its proceeding to address Unresolved issues related to the accessibility of telecommunications and broadcasting services to persons with disabilities. The Commission extended the existing message relay services requirement to include a requirement to provide IP Relay Service. The Commission also determined that further investigation into the projected use, size of individual ASL or LSQ Video Relay user markets, and cost of providing Video Relay service (VRS) in Canada is required. In this regard, the Commission considered that information resulting from the Video Relay initiatives, including the 18-month trial completed by TELUS via its third-party provider Sorenson, as approved in Telecom Decision 2008-1, would be vital to determining whether a follow-up proceeding on VRS is warranted. Please refer to the news release dated 25 May 2012 at <http://www.crtc.gc.ca/eng/com100/2012/r120525.htm>.

The Commission has received and reviewed TELUS’ Video Relay Services Trial – Final Report filed on 14 March 2012 as part of the Decision 2008-1 process.  The Commission requests that TELUS provide responses to the questions in the attachment to this letter no later than 26 June 2012. Where information is coming directly and solely from Sorenson, Sorenson may wish to file a separate response directly with the Commission.

Please contact Kay Saicheua (kay.saicheua@crtc.gc.ca) at (819) 934-1358 should you have any questions in regard to this letter.

Yours sincerely,

ORIGINAL SIGNED BY /

Nanao Kachi
Acting Director
Social & Consumer Policy

Att.

Interrogatories regarding the Sorenson/TELUS Canada Trial

  1. The TELUS final report submits costs categorized under “external vendor costs” and “Internal TELUS Costs”. Please provide a breakdown of the “external vendor costs” associated with providing the Canadian trial.
  2. As Sorenson is not a regular participant in the Commission’s processes, Sorenson may wish to consult section 39 of the Telecommunications Act (S.C. 1993, c.38).

    table

    *where applicable

  3. Given that Sorenson currently has VRS call-centres located in Canada to provide video relay services to clients in the United States; describe how the Canadian video relay traffic was identified and managed in relation to that of the United States. Quantify any effect this had on costs. If economies of scale were experienced, indicate whether they were accounted for in the costs identified above.
  4. In TELUS’ Final Report – Table 5, the number of “Active Users” represents roughly 80% of the “Installed Participants”.
    1. Identify any perceived post-installation barriers to adoption, and indicate whether these were identified by TELUS/Sorenson or through participant feedback.
    2. Describe the manner in which the VRS trial was advertised; and how participants for the trial were solicited and registered. List what relevant information was provided to potential participants.
    3. List the requirements participants needed to meet to qualify for the trial.
    4. Indicate the number of customers who declined an offer to participate in the TELUS VRS trial. If applicable, indicate what their decision was based on.
  5. The TELUS Final Report states that a subscription to TELUS’ high speed Internet was required to qualify for the trial.
    1. Justify this requirement.
    2. Describe any impediments to providing this service to non-TELUS subscribers.
    3. Indicate whether the trial was offered via a managed-IP network or the public Internet; and whether service provision over a managed-IP network would be advisable. Provide your rationale, and the pros and cons under each scenario.
  6. The Canadian trial required the use of Sorenson videophones which were professionally installed by a Sorenson technician.
    1. Describe the advantages to providing a VRS solution based on specialized end-user hardware versus a software solution. Describe the different resource considerations that would apply to either solution.
    2. The trial highlights that roughly 70% of video traffic was point-to-point and did not require the services of a video relay operator. Given the widespread availability of non-VRS videoconferencing tools available on the market, based on your understanding, explain why the Canadian trial recorded such a high proportion of point-to-point calls.
    3. The participant survey completed during the trial, and submitted as part of the TELUS Final Report, revealed that more than 1 in 4 participants experienced technical difficulties. The majority of them reported a “black screen” or disconnection of service. Please describe the potential causes for these technical difficulties and whether they were resolved during the trial.
    4. Based on Sorenson’s experience in the United States, describe the cost and technological challenges to providing a bilingual user-interface.
  7. TELUS’ Final report included the submission of a participant survey. The participant survey revealed that there is consumer demand for a mobile VRS solution.
    1. In Sorenson’s experience, explain how such a demand could be met.
    2. Describe the challenges and benefits of such a solution.
    3. In Sorenson’s experience, describe how partnerships with wireless network providers promoted the provision of a mobile VRS solution.
  8. TELUS’ trial did not include access to 911 services via VRS communication.
    1. Although participants were advised not to use Video Relay services for emergency calls during the trial period, indicate whether emergency calls were received and if so the number of emergency calls received throughout the trial.
    2. Based on Sorenson’s experience in the United States, describe how access to 911 services via VRS communication in Canada could be implemented. In your response, indicate what the projected cost of 911 relay implementation in Canada would be.
  9. TELUS undertook a consultative process before and during the trial. Provide the number of attendees for each town hall meeting and teleconference session, highlighting the number of organizations represented and the number of individuals represented. Provide a list of the organizations that form the BC VRS Consultative Committee.
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