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Ottawa, 17 February 2014
File No.: 8620-P8-201400845
By e-mail: jfleger@piac.ca; alau@piac.ca
Public Interest Advocacy Centre and Chimo Community Services
c/o Public Interest Advocacy Centre
1 Nicholas Street, Suite 1204
Ottawa, ON K1N 7B7
RE: Part 1 Application. File # 8620-P8-201400845
Dear Madam/Sir:
The Commission is in receipt of a Part I application from Public Interest Advocacy Centre (PIAC) and Chimo Community Services (Chimo) regarding charges for wireless calls to helplines, dated 29 January 2014. Commission staff requests that you respond to the following questions by 3 March 2014.
1) In your application, you requested that the Commission
(i) Require wireless service providers (and resellers of wireless services) to provide access to helplines at no cost to users or the helplines in question. (paragraph 5, page 4 of your application)
(a) Please define a “helpline”. In your response indicate what criteria should be used to qualify helplines for this cost exemption for its users and how such criteria could be verified. For example registered charity, non-commercial services, services in the public interest, or services which hold social value etc.
(b) Based on your definition of “helpline”, estimate the number of helplines that would qualify and trigger this cost exemption for its clients.
(c) In the instance PIAC and Chimo have explored the technical mechanism that wireless service providers (WSPs) could use to identify these helplines for their billing purposes, please provide the results of your research.
(d) Please clarify the costs to the helpline to which your application refers. That is, confirm whether the intended request is to ensure that no additional charge be applied to the helpline in question to recover the cost of the wireless fees waived for the client.
(e) Based on Chimo’s experience, provide an estimate of the percentage of calls to its helpline from wireless devices, from landlines and from payphones.
(f) Where additional telecom charges apply to operate a helpline, for example the cost of providing toll-free access to clients, provide the average monthly telecommunications cost. Your response should not include the cost of a landline and it should detail both fixed monthly access fees as well as per-minute or usage based fees.
2) Identify how your proposal is different from 2-1-1 services, or alternatively, identify how 2-1-1 services could be further developed to address the needs identified in your application.
3) Paragraph 22 of your application states that “agencies which operate helplines consistently stress that alternatives such as, for example, SMS text messaging would not be a viable substitute for voice communication for the provision of crisis and counseling support” (paragraph 22 of the application). Identify the reasonableness of other voice alternatives, for example pay phones.
This letter also serves to modify the deadlines for submission of comments to 28 March 2014, with replies due on 7 April 2014. This will allow for additional requests for information, if necessary.
If you have any questions with regards to this letter, please contact Kay Saicheua at (819) 934-1358 or kay.saicheua@crtc.gc.ca.
Yours sincerely,
ORIGINAL SIGNED BY/
Nanao Kachi
Director, Social and Consumer Policy
nanao.kachi@crtc.gc.ca
cc : Distribution list
Kay.saicheua@crtc.gc.ca; Meghan.flood@crtc.gc.ca
Distribution list:
Bell Canada: bell.regulatory@bell.ca
Bell Aliant Regional Communications, Limited Partnership: norma.sherwood@bellaliant.ca
Bragg Communications Incorporated: regulatory.matters@corp.eastlink.ca
Brooke Telecom Co-operative Limited: jim@brooketel.ca
CityWest Telephone Corporation: heather.bishop@cwct.ca
CWTA: keby@cwta.ca; info@cwta.ca
Data & Audio Visual Enterprises Wireless Inc. (Mobilicity): gary.wong@mobilicity.ca
Execulink Telecom Inc.: jonathan.scott@execulink.com
Globalive Wireless Management Corp./Yak Communications (Canada) Corp: lisajackson@globalive.com
Hay Communications Co-operative Limited: a.schneider@hay.net
Huron Telecommunications Co-Operative Limited: grubb@hurontel.on.ca
Mornington Communications Co-operative Limited: lhallahan@mornington.ca
MTS Inc.: iworkstation@mtsallstream.com
Nexicom Telecommunications Inc.: jdowns@nexicomgroup.net; pdowns@nexicomgroup.net
Public Mobile Inc.: Jamie.greenberg@publicmobile.ca
Quadro Communications Co-operative Inc.: barry.stone@quadro.net
Rogers Communications Partnership: david.watt@rci.rogers.com; rwi_gr@rci.rogers.com
Saskatchewan Telecommunications: document.control@sasktel.sk.ca
Sogetel Inc./ Téléphone Milot Inc.: sophie.houde@sogetel.com
SSi Micro Ltd.: regulatory@ssimicro.com
TBayTel: rob.olenick@tbaytel.com
TELUS Communications Company: tom.woo@telus.com; regulatory.affairs@telus.com
Vidéotron G.P.: regaffairs@quebecor.com
Wightman Telecom Ltd.: kgugan@wightman.ca
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