Telecom Procedural Letter addressed to Philippe Gauvin (Bell Canada)

Ottawa, 14 April 2020

File No. 8662-B2-201912626


To: Bell Canada
c/o Mr. Philippe Gauvin, Assistant General Counsel
160 Elgin Street, Floor 19
Ottawa, Ontario
K2P 2C4

RE: Part 1 Application For Exemption From Certain Reporting Requirements Pursuant To Telecom Regulatory Policy CRTC 2018-466, Review Of The Regulatory Framework For Text-Based Message Relay Services

Dear Mr. Gauvin: 

The Commission is in receipt of a part 1 application, dated 20 December 2019, by Bell Canada (Bell) in which the company requests a permanent exemption from an element of a reporting requirement relating to Teletypewriter (TTY) relay service.

Specifically, Bell has requested an exemption from the requirement that annual indicators and reporting requirements for message relay service be broken down by wholesale versus retail TTY relay service. 

In order to assist in the analysis of the application, the Appendix to this letter sets out questions for Bell to answer by no later than 12 May 2020. Bell is also requested to repeat each question in its reply.

In light of this request for information, following Bell’s responses to questions, parties to the proceeding may respond to this new information by 1 June 2020 and Bell may reply by 16 June 2020.

As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Telecommunications service providers (TSPs) may designate certain information as confidential. TSPs must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

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

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

Yours sincerely,

Original signed by

Nanao Kachi
Social and Consumer Policy
Consumer, Research and Communications

c.c.: Albert Xie, CRTC,
Lisa Anderson, DWCC-CSSSC,
Jim Roots, CAD-ASC,
Megan McHugh, CNSDB,
Elliott Richman, DAANS,

Appendix 1

Request for information

Provide the following information to clarify the details of your application.

In section 3.0 of its application, Bell indicated that its wireline and wireless third-party TTY relay service providers would be unable to distinguish between wholesale and retail TTY relay customers due to the inherent design and structure of their current network infrastructures, and that any solutions would be financially unreasonable.

  1. Please elaborate on this position, providing more details regarding the specific financial challenges and technological challenges Bell outlined in its application.
  2. Please provide more details on what would be required technologically and financially to allow these TTY relay service provider networks to be able to distinguish between wholesale versus retail TTY customers for data reporting purposes.
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