ARCHIVED - Letter
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Ottawa, 28 May 2013
BY E-MAIL
Teresa Griffin-Muir
Vice President, Regulatory Affairs
MTS Allstream
Suite 1400
45 O’Connor Street
Ottawa, Ontario K1P 1A4
iworkstation@mtsallstream.com
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 communities, CRTC file # 8636-C12-200817505, 8636-C12-200817512, 8626-C12-200817520 – MTS Allstream application
Dear Ms. Griffin-Muir:
In the above application, MTS Allstream proposed to use Deferral Account accessibility funds to cover costs related to accessibility enhancements to its mts.ca website, Internet Protocol (IP) Relay service, and Text Messaging to E9-1-1 (T9-1-1). Furthermore, in its 15 March 2013 reply to Commission staff’s request for information, MTS Allstream proposed to fund the development of described video (DV) and closed captioning (CC) hot keys on its television remote using the deferral account.
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 respond to the attached request for information on or before 7 June 2013. All parties may submit reply comments pertaining to the additional information provided to the Commission by 17 June 2013.
Yours sincerely
{Original signed by}
Nanao Kachi
Director, Social and Consumer Policy
Consumer Affairs and Strategic Planning
cc: Greg Milosek, CRTC gregory.milosek@crtc.gc.ca
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
bell.regulatory@bell.ca
regulatory.affairs@telus.com
document.control@sasktel.sk.ca
regaffairs@quebecor.com
telecom.regulatory@cogeco.com
Regulatory@sjrb.ca
alexander.adeyinka@rci.rogers.com
Requests for Information
MTS Allstream’s proposed “Website Accessibility Enhancements”
1. Has MTS Allstream consulted with organizations for persons with disabilities in regard to its proposed website accessibility enhancements? If yes,
a. Specify the organization(s) that MTS Allstream consulted with; and
b. Provide any feedback from this organization(s) in regards to MTS Allstream’s proposed website accessibility enhancement, including the proposed single search initiative.
2. Specify by percentage the extent to which MTS Allstream’s proposed accessibility enhancements to mts.ca apply to Telecommunications products and services, as opposed to Broadcasting products and services.
3. In Decision 2006-9, the Commission determined that the disposition of funds in the deferral accounts should primarily provide benefits to residential customers. Commission staff notes that allstream.com is focused exclusively on serving Canadian business customers.
Explain how MTS Allstream’s proposed website accessibility enhancements to allstream.com will i) improve accessibility to telecommunications services for persons with disabilities, and ii) primarily benefit residential customers, with supporting rationale.
4. Specify the extent to which the proposed website accessibility enhancements would ensure compliance of MTS Allstream’s websites to the requirements of any provincial legislation, or pending legislation, that governs the jurisdictions where MTS Allstream does business. Include in your answer justifying rationale as to why meeting the obligations of any provincial legislation is an appropriate use of deferral account funds.
MTS Allstream’s proposed “Text Messaging to E9-1-1 Service (T9-1-1)”
5. In Decision 2006-9, the Commission determined that the principle of competitive neutrality was an important factor in evaluating proposals to dispose of deferral account funds.
Explain how MTS Allstream’s proposal to draw down its deferral account to fund the development of T9-1-1 is consistent with the principle of competitive neutrality in light of the fact that all wireless carriers and incumbent local exchange carriers are required to implement T9-1-1, with supporting rationale.
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