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Ottawa, 9 July 2012

File Nos. 8678-S22-201206756
               8678-C12-200905557

Mr. Robert Hersche
Director, Regulatory Affairs
Saskatchewan Telecommunications
2121 Saskatchewan Drive
12th Floor
Regina, Sk
S4P 3Y2
Email: document.control@sasktel.sk.ca

Re:  Amended Procedures for SaskTel Part 1 Application, Use of Deferral Account funds to improve access to telecommunications services for persons with disabilities

Dear Mr. Hersche:

With this letter, Commission staff is amending the process for Saskatchewan Telecommunications’ (SaskTel’s) Part 1 application in order for Commission staff to issue further interrogatories to SaskTel.  These are provided in the attachment to this letter.

SaskTel’s Part 1 Application

SaskTel filed an application1 on 4 June 2012, pursuant to Part 1 of the CRTC Telecommunications Rules of Practice and Procedure (the Rules) and in accordance with a request in a Commission letter dated 1 May 2012.2  In its Part 1 Application, SaskTel submitted a proposal to utilize the outstanding amount of funds remaining in its deferral account.  The proposal consists of three accessibility initiatives, listed below and described in greater detail in SaskTel’s application. 

SaskTel requested the Commission to expeditiously approve these three initiatives in order for SaskTel to begin implementation of these initiatives as soon as possible.

Amended Process

Considering SaskTel’s request for the expeditious approval of funding and the need for persons with disabilities to take advantage of the initiatives provided for in SaskTel’s proposal, the Commission expects to issue a decision as soon as feasible after the record closes.

Documents to be filed and served in accordance with the above process must be received, not merely sent, by the dates indicated.

Yours sincerely,

ORIGINAL SIGNED BY:

Mary-Louise Hayward
Manager, Social & Consumer Policy
Policy Development and Research

Attachment:  Interrogatories to SaskTel

Distribution List:

Canadian Association of the Deaf jroots@cad.ca; ARCH archlib@lao.on.ca;  petricoi@lao.on.ca; Council of Canadians with Disabilities, laurie@ccdonline.ca; Council of Canadians with Disabilities, ccd@ccdonline.ca; Independent Living Canada, nationaldirector@ilc-vac.ca;  Canadian National Institute for the Blind (CNIB), Christine.robbins@cnib.ca; Canadian Council of the Blind, mpotvin@ccbnational.net; The Canadian Hearing Society, ckenopic@chs.ca; Canadian Association for Community Living, mbach@cacl.ca; Centre québécois de la déficience auditive, cqda@videotron.ca; Public Interest Law Centre, mybow@legalaid.mb.ca; Disability and Information Technologies (Dis-IT), ine@ccdonline.ca; d_stienstra@umanitoba.ca; Alliance for Equality of Blind Canadians/L'Alliance pour l'égalité des aveugles canadiens, mworkman@blindcanadians.ca; Farah.mughal@rci.rogers.com; Neil Squire; Society, garyb@neilsquire.ca;  Chris Stark, stark.chris@rogers.com; jeff.in.kanata@gmail.com; Clayton Zekelman, clayton@MNSi.Net; Beverley Milligan, Media Access Canada, bmilligan@mediac.ca

ATTACHMENT

A. Response to 1) of SASKTEL(CRTC)1MAY12-B1-7 FOLLOW-UP D08-1

SaskTel provided the following information.

Research shows that telecommunication products and services are underutilized by persons with intellectual disabilities.  Part of this underutilization can be attributed to the cost of telecommunications services, which are often financially out of reach for persons with intellectual disabilities, in addition to a general lack of knowledge and training and support regarding the use and benefit of telecommunications products and services.  RDACL members are no different, and require support in order to access all types of telecommunications services in order to promote their ability to participate meaningfully in society and the economy.  The proposal put forth by SaskTel and RDACL will attempt to create an effective system of access to telecommunications products and services, be it basic wireline telephony, wireless service or broadband Internet access, in addition to providing persons with intellectual disabilities the support required in order to utilize and benefit fully from the underlying technology.  Training and support is not a new concept to RDACL.  RDACL founded the Campus for All in Regina, which is a Degree course at the University of Regina for the intellectually handicapped individuals.  Increased access to telecommunications would dramatically enhance graduates ability to meaningfully participate in society and the economy.  However, too often as in this case, items such as wireless devices and associated service plans are just not affordable.  RDACL would see a program providing the hardware, upkeep and any training necessary for any individuals in circumstances such as these.  Other programs, such as the Next Chapter Book Club and Best Buddies Program could be enhanced through the improved use of the Internet to provide access to e-books and increased interaction between individuals across geographic boundaries.  As with other programs, telecommunications access is a small part of the overall experience, with training and support being required to ensure that individuals with intellectual disabilities are receiving the full benefit from technology.

  1. Provide detailed information as to how RDACL will use these funds in order to improve access to telecommunications services by persons with intellectual disabilities.  Include in your answer:
    1. An overview of the ‘program’ or approach that RDACL plans take in order to “establish an effective system of access to telecommunications products and services.”  Include details pertaining to:
      1. The needs of persons with intellectual disabilities with regard to access of telecommunications products and services.
      2. How the approach that will be used by RDACL will address these needs and will result in improved access to telecommunications services for these persons.
      3. Desired outcomes and the criteria that will be used to measure success of these outcomes in terms of the effectiveness of the program.
      4. The telecommunications services, devices, products, etc. that will be utilized in RDACL’s approach, and how they will be utilized.
    2. The approach that RDACL will take to evolve its approach in order to accommodate changing technologies and changing needs of persons with intellectual disabilities.  Explain with substantiating detail how the benefits of this initiative will be sustained once utilization of these funds has been completed.
    3. The approach that RDACL plans to take, and the resources that it will use, to manage this initiative.  Confirm that the required resources are in place.
  2. Is it Sasktel’s view that its proposed Association of Community Living proposal is consistent with the guidelines set out in Telecom Decision 2006-9 for initiatives to improve accessibility to telecommunications services by persons with disabilities?3  If yes, support this view with substantiating detail.
  3. The Commission has in place a policy4 that, amongst other things, addresses access to mobile wireless telecommunications services by persons who have moderate-to-severe cognitive disabilities.
    1. In its approach to “establishing an effective system of access to telecommunications products and services” does RDACL plan to address access to mobile wireless telecommunications services for its members who have intellectual disabilities including those with moderate-to-severe cognitive disabilities?
    2. If yes, provide details of RDACL’s approach to addressing access to mobile wireless telecommunications services by these persons.

B. Response to 7) of SASKTEL(CRTC)1MAY12-B1-7 FOLLOW-UP D08-1

SaskTel provided the following information.

The objectives of the program would be set out in concert with SaskTel, but at the discretion of RDACL.  These objectives would be reported on at regular intervals.  If at any time it was concluded by a third Party - to be named in the agreement - that the agreement was not being carried out in good faith, the funds could be frozen until suitable arrangements were made.

  1. Provide details as to the structure and content of the proposed reporting.
  2. Provide SaskTel’s view as to the criteria that would indicate “that the agreement was not being carried out in good faith.”

C. Response to SASKTEL(CRTC)1MAY12-C2 FOLLOW-UP D08-1

SaskTel provided the following information.

SaskTel does not own in-building copper wire in MDU’s, and as such it is the responsibility of the building owner to ensure that the in-building wire is capable of providing broadband services.  The proposed upgrade will ensure that each of the MDUs identified have the most current up-to-date in-building facilities in place, at no cost to the building owner, to ensure that residents within that building will have access to broadband Internet and television services should they choose to subscribe to such services in the future.

  1. Who will be the owner of the upgraded in-building wire: SaskTel or the building owner?  If the building owner is to take ownership of the upgraded wire, specify whether that arrangement will be covered by a transfer document.

D. Website Accessibility Initiative

Provide a detailed economic study.  Include a breakdown of costs into major cost components, with supporting methodology and assumptions for each major cost estimate.  Include also the study period years in which the costs will be incurred.

[1] http://www.crtc.gc.ca/part1/eng/2012/8678/s22_201206756.htm

[2] http://www.crtc.gc.ca/eng/archive/2012/lt120501b.htm, Commission Letter 2012-05-01.

[3] See paragraph 9 of Telecom Decision 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, http://www.crtc.gc.ca/eng/archive/2008/dt2008-1.htm

[4] http://www.crtc.gc.ca/eng/archive/2009/2009-430.htm Broadcasting and Telecom Regulatory Policy CRTC 2009-430, Accessibility of telecommunications and broadcasting services, paragraph 40 to 46.

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