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Telecom - Commission Letter addressed to the Distribution list

Ottawa, 4 October 2021

Our reference: 1011-NOC2017-0033

BY EMAIL

To: Distribution list

Re:  Follow-up actions regarding reports submitted by CWTA and CISC, pursuant to the CRTC’s Message Relay Services Regulatory (MRS) Policy and concerning the implementation of real-time text relay service over wireline and wireless networks

Background

The Commission is in receipt of the following industry reports (the Reports) as originally requested in Telecom Regulatory Policy CRTC 2018-466 (“2018 MRS Policy”):

  1. A report filed by the Canadian Wireless Telecommunications Association (CWTA) on behalf of Bell Canada, Rogers Communications Canada Inc., Shaw Telecom G.P., TELUS Communications Inc., and Videotron Ltd. on 31 December 2019 reporting on plans and time frames to support real-time text (RTT). This report can be found on the Closed Notices of Consultation section of the Commission's website by clicking the link titled Responses to annual requests for information regarding Message Relay Services.
  2. A report filed by the CRTC Interconnection Steering Committee (CISC) on 26 October 2020 examining a number of technical aspects required to implement a RTT relay service on wireless networks.
  3. A report filed by CISC on 14 December 2020 providing an annual update on the development of RTT standards for wireline IP networks and the feasibility of implementing a wireline RTT relay service.

In the 2018 MRS Policy, the Commission considered the future of MRS, in light of the transition to IP-based networks in Canada. In the course of the proceeding resulting in the 2018 MRS Policy, the information provided to the Commission was that the telecommunications industry was moving towards a wider adoption of RTT technology, including for commercial use, to replace Teletypewriter (TTY) technology. Given that Deaf, deafened, hard-of-hearing, and speech-impaired persons have for years been accessing TTY relay service and that the service will eventually become unreliable as networks become IP-based, the Commission noted in the 2018 MRS Policy that it may, if appropriate, mandate the provision of a RTT relay service following receipt of the Reports.

Summary of the CWTA industry report on plans and time frames for supporting a RTT relay service on mobile wireless networks

Pursuant to paragraph 208 of the 2018 MRS Policy, the CWTA report addresses the following task deliverables:

  1. Wireless service providers’ (WSPs) plans and time frames for their mobile wireless operations to support a RTT relay service (either directly or by outsourcing the provision of the service to a third party)
    • The CWTA report indicates that RTT relay services exist in a limited manner around the world, and that more research would be required in order to examine various implementation options and to determine what would be appropriate in a Canadian context. As such, the larger WSPs have no immediate plans to develop a RTT relay service.
    • Should the Commission mandate the provision of RTT relay service, the report estimates a 21 to 30 month implementation timeline to include activities such as RTT vendor selection Footnote1 and RTT network readiness. Footnote2
  2. How RTT relay service would meet the minimum requirements set out in Appendix 1 of the 2018 MRS Policy
    • The report indicates that such a service would meet the same quality of service requirements that currently exist for MRS, although it cautions that unforeseen challenges specific to RTT relay service may arise during implementation stages.
  3. The consultations with persons with disabilities that have been undertaken
    • The report indicates that preliminary consultations with accessibility groups have been undertaken and feedback has been collected in regards to the minimum service standards and ease of use for this future MRS service.
    • The report notes that it would be more beneficial to undertake any additional consultations as the service is being developed and deployed.
    • In addition, the report mentions that it would be beneficial for the Commission to postpone further consideration of RTT relay until accessibility groups have had the opportunity to use and consider the new and upgraded IP Relay platform and app, which were implemented per the requirements of the 2018 MRS Policy, and may render RTT relay redundant and unnecessary.

Summary of CISC report that presents its findings on RTT technology on wireless networks

Pursuant to paragraph 205 of the 2018 MRS Policy, the CISC report addresses the following task deliverables:

  1. How RTT over mobile wireless networks could be implemented
    • The CISC report discusses how RTT technology could be implemented in a way that would allow RTT communications to travel across the networks of different WSPs (referred to as RTT Peering in the report) and provides a phased approach with timelines for such an undertaking.
    • However, CISC also notes that implementing RTT relay does not require RTT peering, as there are more efficient ways of rolling out RTT relay. Specifically, WSPs only need to connect to an RTT relay call centre, in which case RTT-based services may be implemented natively or using over-the-top (OTT) applications or a mix of both, without the need to implement RTT peering between WSPs. The RTT relay call centre would receive RTT calls and connect the called party using voice/TTY. The RTT relay centre could technically also bridge two RTT sessions if there was such a need.
  2. Within what timelines it could be implemented
    • For a complete RTT peering deployment, the CISC report estimates that a timeline of 27 to 39 months from the date of a Commission decision may be required. However, establishment of RTT relay is independent of the RTT peering implementation. For relay-specific implementation timelines, the CISC report points to the CWTA report (described above), which provides estimates of 21 to over 30 months.
  3. Whether it is feasible to implement it
    • The report indicates that the technical feasibility of the technology is not really in question given that it has been implemented in various manners around the world and is currently being implemented for NG9-1-1 applications. However, a requirement for RTT peering would require significant additional technical work and may be challenging from a practical perspective. Canadian WSPs no longer have any plans to commercially offer RTT-based text messaging within and/or between their networks, as many of those WSPs are now planning to implement and deploy more advanced texting services such as Rich Communication Services (RCS). Footnote3
  4. A standard inter-carrier RTT network-to-network interface (NNI) between mobile wireless carriers
    • The report provides a list of technical standards for a standard inter-carrier RTT NNI between WSPs, but notes that this list may be incomplete since there is currently no clear service description. In the case of native RTT relay or an OTT relay app, CISC recommends standards from this list be used in order to provide a common experience for RTT relay service users.

In short, the report confirms that RTT technology is technically feasible at a high-level, but there remain technical questions which are dependent on how such a service is implemented, should the Commission mandate the implementation of RTT technology in some form.

Summary of CISC report monitoring RTT standards for wireline networks

Pursuant to paragraph 211 of the 2018 MRS Policy, the CISC report addresses the single task deliverable to:

  1. Describe the status of the development of wireline RTT standards, until the standards are sufficiently advanced to consider wireline RTT relay service implementation issues
    • The CISC report notes that very little progress on standards for RTT on wireline networks has been made by standards organizations.
    • As such, the report concludes that CISC did not identify any specific RTT standards for wireline networks that can be used for native RTT implementations over wireline networks, and that CISC will continue monitoring the development of such standards to determine whether it would be possible to implement a wireline RTT relay service.

CISC will update the Commission on its findings in its next annual report which is due 14 December 2021.

Commission’s analysis and determinations

Upon review of the Reports, the Commission is of the view that all three reports provide insights into the original areas of inquiry as set out in the 2018 MRS Policy: the service considerations for implementing an RTT relay service, technical considerations for implementing RTT over wireless networks, and technical considerations for implementing RTT over wireline networks.

However, the Commission notes that WSPs indicated in the CISC report on RTT over wireless networks that they had no current plans to adopt RTT technology for commercial use. That report also discusses uncertainties regarding the specific manner in which a RTT relay service could be implemented over wireless networks, which indicates to the Commission that further discussion is needed before the Commission would be ready to mandate a replacement service for TTY relay service. Finally, since TTY relay and IP relay continue to be available and functional in Canada, the Commission is of the view that there is no immediate need for a replacement service for TTY relay.

As set out in the 2018 MRS Policy, the Commission will continue to monitor the annual reports submitted by MRS providers to the Commission as well as MRS-related complaints received by CRTC Client Services. This will allow the Commission to identify any trends and quality issues that may require Commission intervention to ensure that the accessibility needs of Canadians continue to be adequately served by the current MRS arrangements.  Further, in the event a telecommunication service provider’s (TSP’s) wireline network becomes technically unable to support TTY, paragraph 216 of the 2018 MRS policy allows the TSP to seek relief from the requirement to provide TTY relay service. In seeking relief, the TSP must describe its consultations with accessibility groups and its plans for phasing out the service.

In light of the above, the Commission is of the view that it is premature at this time to mandate a RTT relay service, and that holding a future policy proceeding would be the appropriate avenue for the Commission to consider a suitable replacement for TTY relay, and for interested persons to identify what features a future relay service must offer. The Commission notes that in the 2018 MRS Policy it expressed its intent to review MRS in five years from the date of that Policy.  That review would, amongst other things, be the opportunity to consider how the functionality of TTY relay could be delivered into the future.  

Accordingly, the Commission accepts the Reports and thanks the CWTA and the participants of the CISC for their work on these reports.

Sincerely,

Claude Doucet
Secretary General

Distribution List
Richard Polishak, Richard.Polishak@telus.com
Bell Canada, bell.regulatory@bell.ca
CWTA, communications@cwta.ca
Rogers Communications Canada Inc., rwi_gr@rci.rogers.com
Shaw Telecom G.P., regulatory@sjrb.ca
TELUS Communications Inc., regulatory.affairs@telus.com
Videotron Ltd., regaffairs@quebecor.com

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