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Ottawa, 14 February 2013

File #: 8678-M59-201210434

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


Dear Ms. Griffin-Muir:

Subject: RE: 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, CRTC file # 8636-C12-200817505, 8636 C12-200817512, 8626-C12-200817520 – MTS Allstream application

In the above application, MTS Allstream has proposed the use of $113K of Deferral Account accessibility funds to cover costs related to the MTS Allstream’s participation in the Text Messaging with 9-1-1 (T9-1-1) trial, including network preparation and handset testing, to name two. This proposal and the rationale for the proposal was submitted in the context of the trial, before the Commission had made any determination with respect to whether or not the trial would result in the implementation of T9-1-1.

As you are aware, the Commission has recently issued a decision (Telecom Decision CRTC 2013-22) announcing the implementation of a T9-1-1 nationwide:

The Commission … directs wireless carriers and incumbent local exchange carriers to make the changes in their networks, systems, and processes required to support the provision of Text Messaging with 9-1-1 service for hearing- or speech-impaired persons within 12 months of the date of this decision. The Commission also requests the development of a service communications plan and education program that can be used to inform subscribers and the general public of the Text Messaging 9‑1‑1 service.

Given the Commission’s decision in this regard, Commission staff has determined that additional information is required to complete its assessment of MTS Allstream’s application.

Commission staff is thus requesting that MTS Allstream provide further rationale in the context of the Commission’s decision with respect to the reasons why the proposed T9-1-1 drawdown is appropriate and is compliant with the requirements described in Telecom Decisions 2006-9 and 2008-1.

Furthermore, if the Commission were to find that MTS Allstream’s T9-1-1 initiative is not eligible for deferral account accessibility monies, Commission staff is requesting MTS Allstream provide in detail an alternative initiative(s) with substantiating evidence that demonstrates its compliance with Telecom Decisions 2006-9 and 2008-1.

Accordingly, MTS Allstream is to file its responses to the Commission’s request for information on or before 15 March 2013.

As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, MTS Allstream may designate certain information as confidential. The company must provide an abridged version of the document involved, accompanied by a rationale explaining how the information removed is confidential.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

Yours sincerely,

Original Signed by

Nanao Kachi
Director, Social Policy
Consumer Affairs and Strategic Planning

c.c. Pauline Jessome, MTS Allstream (613) 688-8791
Mary-Louise Hayward, CRTC
Attached distribution list
Distribution List

Canadian Association of the Deaf
Council of Canadians with Disabilities,
Council of Canadians with Disabilities,
Independent Living Canada,
Canadian National Institute for the Blind (CNIB),
Canadian Council of the Blind,
The Canadian Hearing Society,
Canadian Association for Community Living,
Centre québécois de la déficience auditive,
Public Interest Law Centre,
Disability and Information Technologies (Dis-IT),
Alliance for Equality of Blind Canadians/L'Alliance pour l'égalité des aveugles canadiens,
Neil Squire Society,
Chris Stark,;
Clayton Zekelman, clayton@MNSi.Net
Beverley Milligan, Media Access Canada,

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