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Ottawa, 24 July 2012

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

Via email:  teresa.griffin-muir@mtsallstream.com
iworkstation@mtsallstream.com

Subject: Use of Deferral Account funds to improve access to telecommunications services for persons with disabilities and to expand broadband services to rural and remote services

Dear Ms. Griffin-Muir:

I am writing regarding deferral account initiatives proposed by MTS Inc. and Allstream Inc. (collectively, MTS Allstream) that are aimed at improving telecommunications services to persons with disabilities (accessibility initiatives).

In 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, the Commission approved MTS Allstream’s proposal to use deferral fund monies to improve the accessibility of its website, including adding accessible information on products and services for customers with visual, physical, hearing and speech disabilities as well as information about other telecommunications products and services that it offers.  The Commission also approved MTS Allstream’s proposal to set aside the remaining funds for specific future initiatives, to be identified at a later date, to improve access to telecommunications services by persons with disabilities.  The Commission found in Telecom Decision 2008-1 that a public proceeding is the appropriate vehicle to ensure that the future accessibility proposals meet the requirements of persons with disabilities and Telecom Decision 2006-9, Disposition of funds in the deferral accounts.

Accordingly, the Commission directed the ILECS to submit their future accessibility proposals for Commission approval.

Proposed future initiatives

In a 29 July 2011 letter to the Commission, MTS Allstream proposed to use its deferral account to fund initiatives related to the following:

Staff requests that MTS Allstream submit a formal application for Commission approval of these initiatives under Part 1 of the CRTC Rules of Practice and Procedure (the Rules).

In reviewing the documents provided by MTS Allstream, staff notes that the proposals related to IP Relay, T9-1-1 and website portal development were not served on any party.  Staff requests that when MTS Allstream files its Part 1 application, it ensures compliance with the Rules, including the requirements related to document service. MTS Allstream is to serve its application on the enclosed list of parties to Telecom Decision 2008-1 who commented on the accessibility-related issues in that proceeding, on or before

24 August 2012.

In its application, MTS Allstream should ensure to include answers to the following questions:

1)  In its updated annual report on Accessibility initiatives dated 29 July 2011, MTS Allstream proposes a draw-down of $113,000 from its deferral account to fund a text

9-1-1 (T9-1-1) initiative.  MTS Allstream provides further information on this initiative in a letter to the Commission dated 5 January 2012 where it confirms that it actively participates in the CISC Emergency Services Working Group (ESWG) meetings in order to support current T9-1-1 efforts that will ready MTS Allstream for the eventual launch of T9-1-1 across Canada. 

Staff notes that, while MTS Allstream is currently working with the ESWG on developing a national database, it is not taking part in the T9-1-1 trial that is currently underway. Please explain why it is appropriate for MTS Allstream to draw-down from its deferral account to fund an initiative that is already being tested by other providers.

2) Staff notes that in Telecom Decision 2006-9, the Commission states that draw-downs from each ILEC’s deferral account must be applied within its own territory.  MTS Allstream confirmed that, although T9-1-1 is of benefit to MTS Allstream in its own territory, the solution that is being implemented is being done so at the national level.  Please clarify how this initiative meets the criteria set out in Telecom Decision 2006-9.

Described Video and Closed Captioning

The Commission considers described video (DV) and closed captioning (CC) to be very important services that make television services more accessible for persons with disabilities.  Staff notes, however, that in Telecom Decision 2006-9, the Commission established that draw-downs from the deferral accounts must fund initiatives that improve accessibility to telecommunications service for persons with disabilities. 

Staff is of the view that, because DV and CC are not telecommunications services, this proposed initiative falls out of scope. 

Finally, staff also asks MTS Allstream to provide the Commission with a final accounting which sets out the remaining amount left in its deferral account as well as proposals, consistent with Telecom Decision 2006-9, for the disposal of the remaining funds, on or before 24 August 2012.

Sincerely,

ORIGINAL SIGNED BY /

Nanao Kachi
Acting Director, Social and Consumer Policy

c.c. mary-louise.hayward@crtc.gc.ca

Encl: Distribution list for parties to Decision 2008-1 who commented on the accessibility-related issues.

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