ARCHIVED -  Letter

Ottawa, 25 May 2012

File No.:  8665-C12-200807943

BY EMAIL

To: Distribution List (attached)

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 (Bell Feasibility Study and TELUS trial), as approved in Telecom Decision 2008-1, would be vital to determining whether a follow-up proceeding on VRS is warranted. The Commission reiterated its determination that Bell Canada and TELUS Communications Company were to implement their respective initiatives by 31 December 2011. The Commission considered that the timeframe would allow for actual information pertaining to the use, cost and rates of IP Relay and TTY Relay to become available. This information would be relevant to such a proceeding. 

The Commission has received and reviewed the Final Report of the Feasibility of Video Relay Service (VRS) for Canada originally filed 24 February 2012 by Mission Consulting on behalf of Bell Canada (amended 4 April 2012), and TELUS’ Video Relay Services Trial – Final Report  filed on 14 March 2012 as part of the Decision 2008-1 process. In order to make a determination on whether a follow-up proceeding is warranted, the Commission needs to establish the availability of relevant information.  Please refer to the news release dated 25 May 2012 at <http://www.crtc.gc.ca/eng/com100/2012/r120525.htm>.

Accordingly, those parties that provide IP Relay and TTY Relay services, either directly or through a third-party, are to provide responses to the questions in the attachment to this letter no later than 26 June 2012.

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.

Distribution list

Bell Canada and Bell Mobility (Bell Mobility, Virgin Mobile, Solo)
Bell Aliant Regional Communications, Limited Partnership (including all of its mobile/wireless operations)
MTS Allstream Inc. (including all of its mobile/wireless operations)
Northwestel Inc. (including all of its mobile/wireless operations)
Saskatchewan Telecommunications (including all of its mobile/wireless operations)
TELUS Communications Company (including all of its mobile/wireless operations)
Bragg Communications Incorporated (EastLink) - (including all of its mobile/wireless operations)
Cogeco Cable Canada Inc.
Fido Solutions Inc.
Rogers Communications Inc. and Rogers Wireless Partnership
Shaw Telecom Inc.
Vidéotron Ltd. (including all of its mobile/wireless operations)
Primus Telecommunications Canada Inc.

bell.regulatory@bell.ca; regulatory@bell.aliant.ca; iworkstation@mtsallstream.com;  regulatoryaffairs@nwtel.ca; document.control@sasktel.sk.ca; regulatory.affairs@telus.com; regulatory.matters@corp.eastlink.ca; telecom.regulatory@cogeco.com; regulatory.aff@fidomobile.ca; rwi_gr@rci.rogers.com; pam.dinsmore@rci.rogers.com; regulatory@sjrb.ca; regaffairs@quebecor.com; regulatory@primustel.ca   

Interrogatories regarding Message Relay Services (MRS)

All LECs (local exchange carriers) are required to provide TTY relay in their operating territories. Broadcasting and Telecom Regulatory Policy 2009-430 extended the obligation to include the provision of IP relay service. 

Answer the following interrogatories on behalf of your company. Consistent with BTRP 2009-430, message relay services (MRS) shall be read to include both TTY and IP Relay. In your responses to the questions below, please provide separate information for each of the two services where applicable.

1. Does your company provide MRS directly or through a third party provider? If MRS is provided through a third party, identify the name of the party.

2. With respect to the MRS that your company provides, provide a list of the types of services options that are included in addition to the basic text-to-operator service [e.g.,  VCO (voice carry over), HCO (hearing carry over) etc.].  

3. If your company provides MRS to LECs (local exchange carriers) via wholesale arrangements, provide a list of the LECs with which you have such agreements as of 1 May 2012.

4. With respect to the amount ($) that your company collects to provide MRS, provide the following:

• the MRS rate per month assessed to your wireline customers [business and residential] for each year from 2008 to 2011
• the MRS rate per month assessed to your mobile/wireless customers [business and residential] for each year from 2008 to 2011
• the MRS rate per month assessed to your VoIP (voice-over internet protocol) customers [business and residential] for each year from 2008 to 2011
• the MRS rate (per month, year, minutes, or other) assessed to your wholesale MRS customers for each year from 2008 to 2011
• in table format, the total revenue collected for each year from 2008 to 2011 to provide MRS.  Provide a breakdown of this MRS revenue by the following segments: i) wireline customers; ii) mobile/wireless customers; iii) VoIP customers; iv) wholesale MRS revenues; and v) other revenue (e.g., long distance, directory assistance etc.)

Note:

In the case that your company does not assess a specific MRS rate to your customers (e.g.,   if the MRS rate is embedded in the cost of a service), provide either a) the last individual MRS rate charged before the rate was embedded or b) the MRS rate your company imputes.

5. With respect to the amount your company spends on providing MRS (either directly or through a third party), provide the total annual expenditure for each of the years from 2008 to 2011 broken down between TTY and IP relay,  providing separately the capital costs, direct operating expenses and third party costs under each service. Indicate the amount, if any, funded through the deferral account. Identify any amounts which reflect partial years, and the months captured.

For the capital costs line item, provide the associated depreciation and financial expenses or alternatively provide the annual equivalent costs that would be applied over the lifespan of the asset, identifying all costing assumptions.

6. Provide the aggregate statistics on call data, as per the table provided below, differentiating between IP relay and TTY traffic for each of the years 2008 to 2011.

7. Provide the average annual statistics on the distribution of calls by (i) time of day and; (ii) by the day of the week for IP relay and TTY separately. Under each scenario, distinguish between residential and business traffic (based on call origin).

8. List the requirements that need to be met for consumers to register for IP Relay. Indicate whether an Internet and/or home phone service subscription is required. Identify and describe the most basic package(s) that consumers can subscribe to in order to ensure reliable access to these services. In your description, provide the stand-alone price of these subscriptions and any additional fees and taxes that would apply. 

9. The majority of VRS vendors specify recommended upload / download speeds ranging from 256 kbps up/down to 1.5 Mbps up/down. Identify and describe the most basic package that consumers can subscribe to in order to ensure reliable access to these services given the minimum requirement of: (i) 256 kbps up/down is met; and (ii) 1.5 Mbps up/down is met.  In your description, provide the stand-alone price of these subscriptions and any additional fees and taxes that would apply. 

Date modified:

2012-05-25