ARCHIVED -  Letter

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Ottawa, 22 August 2013

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


Dear Ms. Griffin-Muir:

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 communities, CRTC file # 8636-C12-200817505, 8636-C12-200817512, 8626-C12-200817520 – MTS Allstream application

On 05 August 2013, Commission staff issued a letter to MTS Allstream requesting additional information to complete their assessment of MTS Allstream’s application.

On 08 August 2013, the Commission received a request by MTS Allstream to extend the deadline for responses to the request for information to 21 August 2013. Commission staff considers this request is reasonable.

In addition, upon further consideration Commission staff is of the view that some of the questions should be expanded and that additional questions are warranted. Thus the requests for information set out in Attachment A replace the requests for information set out in the letter of 05 August 2013.

Accordingly, Commission staff is requesting that MTS Allstream respond to the requests for information set out in Attachment A, on or before 30 August 2013. All parties except MTS Allstream may submit comments pertaining to the additional information provided to the Commission by 13 September 2013
Yours sincerely,


Nanao Kachi
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy

cc: Antica Corner, CRTC

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,

Requests for Information

MTS Allstream’s proposed “Website Accessibility Enhancements”
1. Please provide a breakdown of the costs associated with this initiative, including a more detailed work breakdown and a separation of the costs associated with enhancements to the website and the website. Explain how the costs were developed and provide all assumptions used. If the expenses are estimated using unit costs based on LUC (i.e. based on activities and labour unit cost(s)), provide a detailed description of each activity, the time estimate, and associated LUC. Provide the methodology used to determine the time estimate for each activity. Identify and describe any capital costs included and provide the installed first cost of each capital item.
2. Confirm whether the website accessibility enhancements to date have been tested by persons with disabilities. If so, describe the nature of the testing and provide the results of the testing.
3. Specify the extent to which the proposed website accessibility enhancements were requested by persons with disabilities, including the priority they place on the project compared to other possible accessibility projects.
4. Refer to Attachment 2 MTS(CRTC)28May13-1 Accessibility Initiatives at page 23:
a. Provide the responses of the members of the Accessibility Forum to the question posed in the last bullet on page 23.
b. Provide the responses to similar questions posed at other Accessibility Forum meetings.
5. Confirm whether MTS plans to deploy the single search initiative to support its entire customer base. Specify any provisions or customizations of the single search initiative that MTS intends to make for the purpose of addressing the specific accessibility needs of customers with disabilities. To what extent does the single search initiative benefit persons without disabilities? Would MTS make these provisions or customizations in the absence of deferral account funds?
6. To what extent do the website “wizards” benefit persons without disabilities? Would MTS make any of the enhancements to the website “wizards” in the absence of deferral account funds?

MTS Allstream’s proposed “Text Messaging to E9-1-1 Service (T9-1-1)”

1. According to the CRTC Interconnection Steering Committee (CISC) Emergency Services Working Group’s (ESWG) report Text to 9-1-1 (T9-1-1) via silent voice call to 9-1-1 Trial Results, 3 October 2012, ESRE0061, “[t]he 9-1-1 SPs unanimously propose that the preferred method of cost recovery of their T9-1-1 costs and charges be a tariff that would be structured in the same way as Wireless Phase I and Wireless Phase II Stage 1.” Please reconcile this unanimous proposal with the request for draw down deferral account monies to cover costs associated with T9-1-1.
2. Please provide more details of the costs associated with the T9-1-1 Gateway. Describe the approach used to determine MTS Allstream’s proportionate share of the T9-1-1 Gateway (trial costs) and T9-1-1 Gateway (Launch Preparation Costs). Describe any costs that are unique to MTS and are not shared.
3. Refer to paragraph 8 of the MTS letter to the Commission of 15 March 2013. Provide details of the discussion on T911 at any of the MTS Accessibility Forum meetings and any other MTS consultations with persons with disabilities.


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