ARCHIVED - Telecom Commission Letter Addressed to Distribution List

Ottawa, 3 February 2017

Our reference:  8640-B2-201600049; 1011-NOC2017-0033

BY EMAIL

To: Distribution List

Re: Notice of Consultation to review Message Relay Service regulatory framework Requests for information

Dear Sir/Madam:

Pursuant to the procedure set out in Review of the regulatory framework for Message Relay Service,^{Footnote 1} Telecom Notice of Consultation 2017-33, Commission staff requests responses no later than 6 March 2017 to the attached requests for information.

This request is intended to obtain updates to the responses to letters sent by the Commission in 2012, 2013, 2014, and 2015.^{Footnote 2}

If you have any questions with regards to this letter, please contact Bradley Gaudet at bradley.gaudet@crtc.gc.ca.

Yours sincerely,

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

Enclosure

Distribution List

• Bell Aliant Regional Communications, LP dave.hussey@bellaliant.ca
• Bell Canada bell.regulatory@bell.ca
• Bragg Communications Inc. (Eastlink) regulatory.matters@corp.eastlink.ca
• Cogeco telecom.regulatory@cogeco.com
• Freedom Mobile Inc. bjones@windmobile.ca 
• MTS Inc. regulatory@mts.ca 
• Northwestel Inc. regulatoryaffairs@nwtel.ca
• Rogers Communications Inc. regulatory.aff@fidomobile.ca; rwi_gr@rci.rogers.com;
• Saskatchewan Telecommunications document.control@sasktel.com
• Shaw Telecom Inc. Regulatory@sjrb.ca
• TBayTel rob.olenick@tbaytel.com
• Télébec Limited Partnership reglementa@telebec.com
• TELUS Communications Company regulatory.affairs@telus.com
• Vidéotron regaffairs@quebecor.com

Appendix

1. Does your company provide MRS directly or through a third party provider? If MRS is provided through a third party:
   • identify the name of the party; and
   • provide a copy of the terms of agreement (or other relevant contract) between your company and the third party provider.
2. With respect to the MRS that your company provides, provide a list of the types of services options that are included in addition to the basic text-to-operator service [e.g., VCO (voice carry over), HCO (hearing carry over) etc.].
3. If your company provides MRS to LECs (local exchange carriers) or other telecommunications service providers (TSPs) via wholesale arrangements:
   • provide a list of the LECs or other TSPs with which you have such agreements as of 31 December 2016;
   • indicate whether such arrangements are for the provision of Wholesale Unbundled Relay Services.
4. With respect to the amount ($) that your company collects to provide MRS, provide the following information by populating the table below:
   • the MRS rate per month assessed to your wireline customers [business and residential] for each year from 2013 to 2016
   • the MRS rate per month assessed to your mobile/wireless customers [business and residential] for each year from 2013 to 2016
   • the MRS rate per month assessed to your VoIP (voice-over internet protocol) customers [business and residential] for each year from 2013 to 2016
   • the MRS rate (per month, year, minutes, or other) assessed to your wholesale MRS customers for each year from 2013 to 2016
   • the total revenue collected for each year from 2013 to 2015 to provide MRS. Provide a breakdown of this MRS revenue by the following segments: i) wireline customers; ii) mobile/wireless customers; iii) VoIP customers; iv) wholesale MRS revenues; and v) other revenue

   Total MRS Revenue Collected

   	2013			2014			2015
   	per NAS rate	NAS	Total revenue	per NAS rate	NAS	Total revenue	per NAS rate	NAS	Total revenue
   Wireline
   Wireless
   VoIP
   Wholesale
   Other
   Total

   Note: In the case that your company does not assess a specific MRS rate to your customers (e.g., if the MRS rate is embedded in the cost of a service), provide the MRS rate your company imputes.

5. As described in Telecom Notice of Consultation 2017-33, MRS call volumes declined each year between 2008 and 2014 due to decreases in TTY call volumes that were not being offset by increases in IP relay call volumes. As such, do you expect TTY relay call volumes to continue to decline across Canada? If so, to what extent, and do you expect your company to face similar declines?

   In addition, complete the table below.

   TTY Relay Data for your Company’s Retail Customers for the period of January 1 to December 31

   	Estimation				Forecast
   	2013	2014	2015	2016	2017	2018
   Number of TTY relay calls placed by your company’s retail customers
   Total number of your company’s clients who utilized TTY relay

6. As described in Telecom Notice of Consultation 2017-33, IP relay call volumes have been increasing in recent years. Do you expect IP relay call volumes to continue to increase across Canada? If so, to what extent, and do you expect your company to face similar increases?

   In addition, complete the table below.

   IP Relay Data for your Company’s Retail Customers for the period of January 1 to December 31

   	Estimation				Forecast
   	2013	2014	2015	2016	2017	2018
   Number of IP relay calls placed by your company’s retail customers
   Total number of your company’s clients who utilized IP relay

7. Apple has built TTY software into the latest iOS release. Previous versions of iOS provided support for connecting an external TTY device to the iPhone, but with the built-in software, a physical TTY machine is not required to make TTY calls from an iPhone.
   • Is your company aware of any manufacturers besides Apple that are offering this functionality?
   • Has your company enabled this functionality for the Canadian market?
   • Will your company be enabling this functionality for the Canadian market? If so, describe concrete plans and timeframe.
8. Certain WSPs’ websites indicate that MRS is not available for calls to emergency services. Does your company make MRS available for calls to emergency services? If not, explain why.
9. Provide the Commission data for your company, from 1 January 2015 to 31 December 2016, for all indicators listed below. An MS Excel template has been provided for your convenience, and should be used if possible. If your company provides both wholesale and retail MRS, provide wholesale and retail data separately, wherever possible.

Indicators regarding Calls

1. Total number of incoming^{Footnote 3} calls (by month)
2. Total number of calls relayed (by month)
3. Total number of calls relayed per month sorted by (i) day and (ii) hour^{Footnote 4} and (iii) language
4. Number of abandoned or unanswered calls per month sorted by (i) day and (ii) hour^{Footnote 5} and (iii) language
5. Average wait time (averaged over one month)
6. Average call duration (averaged over one month)

Indicators regarding Customers

7. Total number of MRS users (actual or estimated) detailed by month where possible
8. Total number of customer complaints (annual) categorized by type of complaint (e.g. wait times, operator-related etc.)

Indicators regarding Operators

9. Number of operators and operator hours per week sorted by (i) English operators and (ii) French operators. If operators perform multiple functions, for example, provide general customer service in addition to providing relay services, the number of operator hours should be specific to the time spent on providing relay services.
10. Average operator typing speed
11. Average operator hourly wage rate for (i) English operators and (ii) French operators
12. Operator qualifications/screening criteria for hiring process

Indicators regarding expenditures

13. Monthly breakdown of expenditures associated to the provision of MRS, detailing:
    • Itemized list of capital assets associated with IP relay and TTY relay and the annual equivalent cost that would be applied over the lifespan of the asset, or alternatively, the depreciation associated with the capital cost and financial expenses
    • Direct operating expenses, with detailed breakdown for operator and network costs
    • Third party expenses, detailing what the expenses cover (i.e. the terms of the contract). This could include the agreed upon quality of service standards, white-label services or products, the provision of branded websites and user interfaces etc.

Question 9, Indicators 1;5-7. Monthly indicators

Question 9, Indicator 3. Total number of calls relayed per month sorted by (i) day and (iii) language

Question 9, Indicator 3. Total number of calls relayed per month sorted by (ii) hour and (iii) language

Question 9, Indicator 4. Number of abandoned or unanswered calls per month sorted by (i) day and (iii) language

Question 9, Indicator 4. Number of abandoned or unanswered calls per month sorted by (ii) hour and (iii) language

Question 9, Indicator 8. Total number of customer complaints (annual)

Question 9, Indicators 9-11. Operators

Question 9, Indicator 13. Expenditures