ARCHIVED - Transcript, Hearing 23 October 2013
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Volume 3, 23 October 2013
TRANSCRIPTION OF PROCEEDINGS BEFORE THE CANADIAN RADIO-TELEVISION AND TELECOMMUNICATIONS COMMISSION
Issues related to the feasibility of establishing a video relay service Telecom Notice of Consultation CRTC 2013-155 and 2013-155-1
140 Promenade du Portage
23 October 2013
In order to meet the requirements of the Official Languages Act, transcripts of proceedings before the Commission will be bilingual as to their covers, the listing of the CRTC members and staff attending the public hearings, and the Table of Contents.
However, the aforementioned publication is the recorded verbatim transcript and, as such, is taped and transcribed in either of the official languages, depending on the language spoken by the participant at the public hearing.
Canadian Radio-television and Telecommunications Commission
Issues related to the feasibility of establishing a video relay service Telecom Notice of Consultation CRTC 2013-155 and 2013-155-1
Lori PopeLegal Counsel
Kay SaicheuaHearing Manager and Manager, Social and Consumer Policy
140 Promenade du Portage
23 October 2013
- iv -
TABLE OF CONTENTS
PAGE / PARA
Noni Warner546 / 3209
MTS Allstream567 / 3322
Tatiana Kamaeva614 / 3645
Bell Aliant Regional Communications, Limited Partnership, on behalf of itself and DMTS, KMTS, NorthernTel, Limited Partnership and Télébec, Limited Partnership, Bell Canada, Bell Mobility and Northwestel Inc.633 / 3753
Saskatchewan Telecommunications731 / 4345
- v -
PAGE / PARA
Undertaking608 / 3590
Undertaking611 / 3616
--- Upon resuming on Wednesday, October 23, 2013 at 0900
3204 THE CHAIRPERSON: Order, please, everyone.
3205 Madam Secretary.
3206 THE SECRETARY: Good morning.
3207 We will now start with the presentation of Noni Warner, who is appearing by videoconference from Dartmouth.
3208 You have 15 minutes for your presentation. Thank you.
3209 MS WARNER (interpreted): Am I supposed to be able to see the Commission? All I'm able to see at this point is the CRTC logo. I'm not sure if I should be able to see people on the other end.
3210 THE CHAIRPERSON: You should be able to see something more attractive than the logo.
3211 MS WARNER (interpreted): Yes, I am able to see the four Commissioners.
3212 THE SECRETARY: This is Jade. They are the Commissioners. That's the staff.
3213 MS WARNER (interpreted): Hello, Jade.
3214 THE INTERPRETER: Hi, Jade.
3215 THE SECRETARY: Hi, Miss Warner.
3216 MS WARNER (interpreted): Thank you for making this possibility available today.
3217 THE SECRETARY: Go ahead, Noni. Thank you.
3218 MS WARNER (interpreted): Oh, I can begin?
3219 THE SECRETARY: Yes, you can.
3220 MS WARNER (interpreted): There are two interpreters sitting off screen and you will see me looking at the interpreters as they sign to me.
3221 Thank you and hello to the CRTC board of Commissioners. My name is Noni Warner. I am a deaf Canadian. I am making this submission today because I want to outline the importance of Video Relay Services in Canada.
3222 I currently am an instructor in the Deaf Studies and the American Sign Language English Interpretation Program at the Nova Scotia Community College. I also have had the opportunity to present workshops over several years on a number of different topic areas.
3223 I have a Master's in Linguistics from (indiscernible) University. I am also a member of the Nova Scotia Video Relay Services Working Group.
3224 In the spring of 2013 a survey was sent out by the CRTC and many deaf individuals here in Nova Scotia felt that the website was challenging and inaccessible. That was the impetus for us setting up a Town Hall here in Nova Scotia to inform people how they would be able to participate in the survey, and as I mentioned, it was a challenge because the information on the website was provided in written English.
3225 The opportunity to have a Town Hall and bring together members of the deaf community along with their friends and supporters and interpreters was extremely important.
3226 We would like to acknowledge the British Columbia Video Relay Services Committee, who really took on the mother lode of responsibility in establishing this passion and making sure that the information was provided to deaf and hard of hearing Canadians and making the point known that we need this service within Canada.
3227 Many Canadian deaf and hard of hearing individuals had the opportunity to use Video Relay Services when it was initially started in the United States six or seven years ago, and certainly, Canadian users were very excited to have that opportunity. Unfortunately, we are no longer able to use that service because, rightly, the United States said they were not going to pay for Video Relay Services to be provided to Canadians.
3228 That was a huge disappointment and loss to the deaf community in terms of having those services. There was a huge impact on deaf individuals when we no longer were able to have Video Relay Services. We no longer were able to readily and easily make contact with those within our intimate circle, and professionally we were not able to make contact with those that we work with and not able to access government services and our elected representatives in the ways that we should be able to.
3229 For the past several years American companies have set up their services and have recruited Canadian interpreters to work within those services, but those interpreters are not providing service or Video Relay Services to Canadian users.
3230 The reason that that Nova Scotia Video Relay Services Working Group wants to promote the provision of Video Relay Services in Canada is that we want to be able to use our own language to be able to access services in an equivalent way to hearing Canadians.
3231 At this point, all we have available is the Maritime Relay Service and that's an antiquated service. We're required to call an operator and use a TTY, which again is in English. There's no tone, there's no intonation within that. We're using a flat two-dimensional technology in a three-dimensional world.
3232 So it's real challenge for users of the Maritime Relay Service to connect with the individual that they want to talk to. They're going through an operator. Again, as I said, they're being required to use English services which may not be the most accessible to them. There's also a lot of confusion that can come along with that because sometimes the meaning within that translation for that individual is not made clear.
3233 With the Video Relay Service, that removes all of those concerns and issues around being able to access information fully.
3234 More and more individuals are using IP Relay. TTYs are an obsolete technology and very few people are using them.
3235 The CRTC should be more proactive, and by that, I mean it's prior to the establishment of the CRTC when telecommunications services were originally being established so that what happened was phone services were set up but deaf people were not considered within that provision of service. Deaf people could not contact their family members, they couldn't contact health providers or their employers. And then in 1973 or somewhere thereabouts TTY services were added.
3236 We are now in a situation again where deaf and hard of hearing Canadians are behind the services that are provided to all other Canadians. Video Relay Services have been available in the United States for more than 10 years, but in Canada we continue to study, we continue to discuss and we continue to delay.
3237 Deaf Canadians need these services. The CRTC needs to be more proactive in terms of being able to set those services up and being able to pull together stakeholders and ask them for the types of services that they would like to see and ask them for their expertise and knowledge in terms of the technology that exists.
3238 I remember when we first were able to send messages back in the eighties through pagers, and then we moved to a V-Box, which was a little blue box that almost looked like text messaging, and deaf Canadians were excited to be able to even have that technology.
3239 And at the time that technology was not of interest to hearing Canadians. And then when Canadians who could hear found out about those services, we started to see more and more people using that.
3240 And over time we've seen a number of other services. Whether it's Android, whether it's Oovoo, whether it's BlackBerry, there are more and more and more services that are available to Canadians and to individuals within the world.
3241 Canada is a G8 country and so deaf Canadians should be able to receive services at a G8 level. Deaf Canadians have been asking for feedback and ideas and working together to try to bring these services forward, and as we've seen with other technologies, in their inception they tend to benefit a smaller group of individuals but over time the application becomes more widespread.
3242 Perhaps the general belief is that the deaf community is a small number of individuals within Canada and if we look at the cost of Video Relay Services it's not cost-effective.
3243 However, if we look at the circles of connection that a deaf individual or deaf communities would have, we look at their families, we look at their employers, we look at their employees and we look at the wider community who are neither able to access them nor are they able to access those individuals.
3244 So we see suffering that doesn't need to happen. We see people not able to contact others in the way that they want.
3245 I look at myself as an individual with a Master's degree and I still am not able to access just basic services.
3246 I remember many years ago, people would ask me questions like "How do you manage to drive a car? How would you be able to survive as a deaf person?"
3247 And when one responds to that and says a deaf person can really do anything, the broader population is surprised to see that. However, we're not able to say that about Video Relay Services because we don't have access to that.
3248 We are not able to be fully participating citizens because we're not able to access whether it's the election process, whether it's health care and so many other services because of the limited access to telecommunication services.
3249 So the question I put forward is, why wait? We have the devices. We have the technology.
3250 As you can see, across Canada you have deaf individuals and organizations who continue to advocate and promote this service.
3251 We want to see a 24-hour/seven day a week service. We want to see inter-operability with the 911 service. And individuals should be able to, if they're on the road, use their mobile device regardless of what platform it is to be able to access services, and those services should be compatible.
3252 I'm also involved with an organization that teaches deaf people to become teachers of American Sign Language. And part of that training provides them with the opportunity to do business training.
3253 And we talk about how an individual would, in American Sign Language or LSQ, be able to run their business. And certainly I am speaking from Nova Scotia, but we are also aware of the issues that impact our LSQ French citizens as well.
3254 We are -- as I mentioned, I teach within an interpreter training program. We are training more and more interpreters every year. The more interpreters we train, the more -- and the more service that we provide, both of those things go hand in hand.
3255 If we had a fully-established VRS service in Canada, we would, at this point, be able to provide that service because we have interpreters and we can provide them with the training.
3256 In 1985 or 1986, there was the NATO Day of -- International Day for Individuals with Disabilities. I remember thinking that that was a wonderful day, and that day was really the impetus for me to start to look at human rights and to learn more about that.
3257 That was inspiring for me and that lit the flame of passion for me as an individual. And I felt proud of Canada as a country that it would support the rights of individuals with disabilities.
3258 I want to thank you for the time to listen to my submission today, and I would be open for questions.
3259 THE CHAIRPERSON: Thank you.
3260 Commissioner Duncan will have some questions for you.
3261 COMMISSIONER DUNCAN: Good morning, Ms. Warner. We're very happy to have you here, and your making time for us. We're interested in your perspective, which certainly is consistent with the message that we've gotten from other deaf people and organizations that have participated.
3262 And it's very helpful, and hopefully will allow us to move along as quickly as possible in this process.
3263 I am interested particularly in the fact that you are involved in the interpreter training program at the Nova Scotia Community College. And I would be --
3264 MS WARNER (interpreted): I am, yes.
3265 COMMISSIONER DUNCAN: I would be interested to know the number of students in the classes and the number that are graduating and how many years that particular program has been in existence.
3266 MS WARNER (interpreted): The program has been in operation since, I believe, 1993.
3267 We have -- we originally had biannual intake for a number of years and then, in 2007, we also established a deaf studies program, and we have annual intake with that program. We accept up to 30 students in the deaf studies program, and that's a prerequisite for the interpreter training program.
3268 Many of the graduates from that program would then apply to enter the interpreter program.
3269 The interest and need was so great that we have now gone to an annual intake for the interpreter training program, and we have an annual application process. And that, of course, will increase the pool of interpreters that will graduate.
3270 We train up to 16 students per group and -- within the annual intake for interpreters, and the reason that the number is small is because it's a visual language, and that level of training required, we keep it to a small group.
3271 COMMISSIONER DUNCAN: Thank you for that.
3272 How many years would it take for a person starting in the deaf studies program, the initial program, and following through to completion in the interpretation study program -- how long would it take to be a qualified interpreter?
3273 MS WARNER (interpreted): The deaf studies program is one year and the interpreter training program is two years, so that would be a total of three years for the actual interpreter training.
3274 However, before a student can enter the deaf studies program, they are required to have taken a basic level of sign language, which may be a number of years.
3275 So for the actual program, it takes three years, but I order to take that prerequisite of the sign language classes, it would be approximately five or six years of training before an interpreter was qualified to begin to interpret.
3276 We do have Sorenson here, an American company, Sorenson, that comes -- that's established here in Dartmouth and has services, so those interpreter students are going into Sorenson and receiving training so as soon as they graduate, they're working for Sorenson, which is a Video Relay Service provider.
3277 So we are actually very fortunate to provide not only the training for interpreters at the community college, but to also partner with Sorenson to provide the Video Relay Service training for those interpreter student graduates.
3278 COMMISSIONER DUNCAN: So the availability of interpreters has been a big point of discussion at the hearing and, you know, accommodating the needs of the deaf community for community interpreting and the -- and competing with the VRS requirement for interpreters.
3279 And I'm just wondering, do you see that as an ongoing problem or are there sufficient interpreters to accommodate both requirements?
3280 MS WARNER (interpreted): That's a very good question, Commissioner Duncan.
3281 When the Video Relay Service was initially started here in Nova Scotia, there were some initial concerns, but what we found was that the interpreters here in Nova Scotia were happy to get that experience of Video Relay Service, but they were doing it mainly on a part-time basis and continuing to work within the community as interpreters.
3282 As I'd mentioned, there is an annual intake for the deaf studies program as well as the interpreter training program, and so we are working very hard at the community college to meet the demand. And if Canada was to establish Video Relay Services, we are set to meet that need here in Nova Scotia.
3283 And I think the CRTC has certainly been talking about -- obviously talking about Video Relay Services. I think that this is wonderful, not only in terms of providing this information to the deaf community, but I think it's wonderful because it makes the broader community of people who can hear know more about these services and, hopefully, will find other opportunities to partner with the broader community.
3284 COMMISSIONER DUNCAN: So in your opinion and based on your experience in Nova Scotia, would you expect that introducing the VRS would negatively impact community interpreters, the availability of community interpreters?
3285 MS WARNER (interpreted): And by negative, Commissioner Duncan, if you mean that there will be not enough interpreters, that would be -- certainly that is a challenge. But as I said, we are already working towards meeting that need. And we have now had the annual intake.
3286 I don't know that it would have a negative impact. We are excited, as a deaf community, and the interpreters are excited to work towards meeting that need.
3287 COMMISSIONER DUNCAN: Thank you.
3288 So you know, a lot --
3289 MS WARNER (interpreted): And the more interpreters that are -- the more interpreters that are needed, that means that it meets the demands of the deaf community because it provides more opportunities for deaf people to obtain employment and be able to maintain that employment with the interpreter availability.
3290 COMMISSIONER DUNCAN: You know, a -- some of the --
3291 MS WARNER (interpreted): Again, we have to continue to build and work together.
3292 COMMISSIONER DUNCAN: Some of the discussion this week -- and you mentioned it in your opening remarks -- is the need for a 24/7 service. And so the question is, you know, how quickly could we ramp up -- if everything is a go-ahead, how quickly could we ramp up to a 24/7 service?
3293 So do you have any view on that? Again, with respect to Nova Scotia, would you be able to start on day one?
3294 MS WARNER (interpreted): That is a good question.
3295 That is something that we certainly need -- requires more investigation. We already had a 911 service through TTY, so perhaps we would have to have some form of balance between the two in the initial inception of the service.
3296 And of course, the Video Relay Service would be something that would be not only set up provincially; it would be a national service. Therefore, individuals would be able to access interpreters from across the country through the Video Relay Service.
3297 COMMISSIONER DUNCAN: Okay. Thank you for that.
3298 I wanted to -- I noticed you mentioned the TTYs, but do you also use the IP relay service as well?
3299 MS WARNER (interpreted): Yes --
3300 COMISSIONER DUNCAN: And --
3301 MS WARNER (interpreted): -- we use the IP relay service. The -- and as -- TTY is really this antiquated technology. The thing with TTY is that one has to actually carry around the device, they have to find somebody else who has that, and it's just -- it's not a -- not a particularly accessible service. IP relay is available anytime anywhere through pretty much any device, so that makes it just a great technology.
3302 COMISSIONER DUNCAN: Okay. I just wanted to go back. In your introductory comments you made a comment which I didn't get the full -- I didn't hear completely and that was with respect to the difficulty you had was it accessing the Commission's website. Did you have difficulty as well with the Notice of Consultation?
3303 MS WARNER (interpreted): Well, the concern and I will -- I will preface my remarks with the caveat that I tend to be very blunt, but I have to say that, yes, I did find the CRTC website accessing the information to be very challenging. It's not particularly user friendly.
3304 COMISSIONER DUNCAN: Okay. That's --
3305 MS WARNER (interpreted): The English is on a level that is not day-to-day discourse. I would say the average Canadian, regardless of their ability to hear, would not feel comfortable using that language or have the -- a facility with that language.
3306 COMISSIONER DUNCAN: Well --
3307 MS WARNER (interpreted): We -- and we also have Canadians who are English as a second language users who are immigrants from other countries, who I don't feel would be able to easily access the information just because of the level of English that it was written at. And certainly if the CRTC plans in future to continue to provide this kind of information, it would be wonderful to bring in a stakeholder, a deaf stakeholder who would be able to -- who was familiar with website design, who might be able to help you make sure that that information is accessible to that segment of the population.
3308 COMISSIONER DUNCAN: Okay, thank you. I know that there are government standards that we work to and I'm sure that staff very much appreciates your comment. And not to worry about being too blunt, that's how we all learn, so we appreciate that.
3309 So those are my questions, Mr. Chairman. Perhaps some others may have questions.
3310 THE CHAIRPERSON: Thank you. I have one. How often do you think you would be using a VRS service, particularly if it had -- if there was a delay in making the call? If there was -- if you had to wait, say, two minutes for a call to be completed, would you -- how often do you see using a VRS service as --
3311 MS WARNER (interpreted): Well, I -- the -- certainly it would be a daily service, and I certainly -- I certainly understand that we would -- as with any service when it's initially started, there might be some bugs that need to be ironed out certainly, but I -- one would call back. It's -- so it's the same as being on hold in a phone tree. It would be a similar kind of thing if one has to wait a moment or two. I don't think that that would be much of a concern.
3312 In terms of IP relay, my experience has been that it's fairly quick, it's a fairly quick service, and I certainly would be using video relay services every day. I would be using them for callbacks. I'd be using them to make contacts with businesses within the community. I would be contacting colleagues at the college that I work with, keeping in contact with some of the students at the college, as well as just ordering a pizza for ordering some takeout for the evening. So certainly I could see myself using video relay services throughout the day every day.
3313 THE CHAIRPERSON: Okay. I'm just trying to get a sense of the level of demand that there would be. So, five or six phone calls a day? Because people are impatient in today's world. And if they have to wait a minute or two minutes, they might just send a text or an e-mail and that's ... So you would make five or six phone calls a day, is that -- or VRS calls, is that what you're guessing?
3314 MS WARNER (interpreted): Well, I certainly would make -- I would say -- I would say that I would use it several times a day. And certainly people would be annoyed if every time they called they had an issue. However, I think in the beginning of the service people would be much more understanding that that's just the initial setup of the service, but of course through time people would expect to see improvements in response time and whatnot. With TTY, what we've been using is so obsolete that two minutes' wait on a video relay service would still be -- considered to be some quite rapid service.
3315 THE CHAIRPERSON: I certainly understand that. But -- so when you say "several", do you mean three or four, or do you mean six to 10? I'm just looking for a number, ballpark. I'm not asking you to sign a contract to it. I'm just looking for your best guess.
3316 MS WARNER (interpreted): I would say anywhere from two to four times per day for myself.
3317 THE CHAIRPERSON: Thank you very much. We enjoyed your presentation. Enjoy the rest of the day.
3318 MS WARNER (interpreted): And again, I would thank the commissioners for providing this opportunity. Goodbye and have a good day.
3319 THE SECRETARY: Thank you.
3320 I will now ask MTS Allstream to come to the presentation table.
3321 THE SECRETARY: Please introduce yourself and you have 20 minutes for your presentation.
3322 MS GRIFFIN-MUIR: Thank you.
3323 Good morning. My name is Teresa Griffin-Muir and I'm the Vice President of regulatory at MTS Allstream. With me today on my left is Pauline Jesome, the Director of Regulatory. And on my right, Grainne Grande, our senior legal counsel.
3324 Continued effort must and should be made to improve accessibility and to enable all Canadians to communicate as effectively as possible.
3325 MST Allstream supports measures that will provide the deaf, hard of hearing, and speech impaired community with better ways to communicate. The challenge in this proceeding is to determine whether or not video relay service is the most effective and efficient way to meet the needs of this community.
3326 This challenge is accentuated by the fact that technology is rapidly changing the way all of us communicate. The ever-evolving devices and applications available today, each new one more sophisticated and intuitive than its predecessor, have introduced a plethora of non-verbal forms of interactive communication - from simple texting to e-mail, to business and social media, to Twitter and even Instagram - all enabling direct communications on a personal level and communications to a wide audience.
3327 The greater communications opportunities offered by technology must inform this process and should be a key factor in deciding whether to mandate (or not) VRS. When making this determination, it is useful to consider carriers' experience with IP relay service. In Manitoba MTS Allstream has had very little take up of IP relay service since its introduction in December of 2010. Actual usage is far lower than was anticipated in the 2008 proceeding that led to the Accessibility Policy, the policy that mandated IP relay service for all local exchange carriers.
3328 Our experience provides an indication that IP relay service is not as effective in meeting the needs of the deaf, hard of hearing, and speech impaired community as was originally anticipated. Also, and maybe more likely, there are now other means that are even more effective.
3329 The relative utility of VRS must also be balanced against the cost of implementation, particularly if there are other perhaps better ways to facilitate communications for the deaf, hard of hearing and speech impaired community.
3330 Unlike TTY-based and IP relay services, VRS requires interpreters that have working knowledge of American Sign language and/or Longue des signes québécoise. Therefore, while the interpretation for TTY-based and IP relay services could be readily done by a telecommunications company's operator services staff, this is not the case for VRS.
3331 MST Allstream, like most telecom service providers, has neither the expertise required to define and deploy VRS, nor the skilled resources needed to administer and operate VRS on an ongoing basis. This is why we have recommended that if there is a mandate for VRS, the responsibility for deployment should reside not only with telecom carriers but also with those who have skill and expertise to manage the service, as well as with the beneficiaries of the service. This approach was recommended in the Mission Report as well.
3332 In the event of a mandate, we support the views expressed by the cable carriers. That is, mandated VRS should be subject to oversight by an independent administrator or board of directors, similar to the board that oversees the CCTS.
3333 This board, which would include telecom service providers and other stakeholders, would be responsible for vendor selection, implementation and the ongoing running of VRS. This will ensure that VRS is optimally implemented and offered in an efficient and cost effective manner.
3334 If there is a decision to mandate service, we recommend a single national VRS provider with the experience and expertise to offer quality service. In our view, there is not adequate demand to accommodate the multiple "competitive" providers, suggested by Sorenson Canada, whose parent company is the leading U.S. VRS provider. However, if a multi-provider solution is desired, we believe that the one suggested by several accessibility groups would be more appropriate -- one with multiple Canadian ASL and LSQ interpreter training programs and interpreter agencies providing service through multiple call centres located throughout Canada.
3335 Each ITP or interpreter agency would simply need to meet the same service requirements and use a common platform. This would ensure that users and devices could interact between the providers.
3336 If VRS is mandated, one platform that warrants consideration is Skype. The submission by the Australian Communication Exchange found that the switch from its initial proprietary technology platform to Skype was beneficial to users, because of their existing familiarity with Skype. Given the use of Skype in Canada, this could be a viable technology platform for this purpose as well.
3337 VRS would also bring with it the need for on-going funding.
3338 Like the cable carriers, our preferred form of on-going funding is through general federal taxation revenues. Failing this our second choice would be funding through a centralized funding mechanism, specifically expansion of the existing National Contribution Fund. Collecting and disbursing VRS funding through the NCF would reduce administration costs relative to establishing an entirely new fund.
3339 In this event, the base of contribution-eligible revenue needs to be expanded, to include internet revenues. Not only is VRS an internet-based service --
3340 THE SECRETARY: I'm sorry. Can you just talk a little bit slower, please?
3341 MS GRIFFIN-MUIR: okay.
3342 THE SECRETARY: Thank you.
3343 MS GRIFFIN-MUIR: Not only is VRS an internet-based service but like wireless, internet revenues are increasing as a proportion of total telecom, while revenues from traditional local and long distance services are declining. Therefore, it only makes sense that these revenues are part of the base used to determine the contribution rate.
3344 If VRS is mandated, we support a phased-in approach, as proposed by many other parties. This would allow for the monitoring of demand and service levels before a full blown, national roll-out. When the service is fully rolled out, costs should be capped at around the $30 million per year level, as recommended in the Mission Report.
3345 Although mandated VRS must be able to accommodate both ASL-English and LSQ-French, whether it should be offered on a 24/7 basis in the longer term, or not, should be determined based on a cost-benefit analysis, taking into account usage patterns during the phase in period.
3346 However, given the rapid pace at which technology is changing we believe that VRS over even the relatively short term, may not prove to be the most efficient and effective means of meeting the communications needs of individuals in the deaf, hard of hearing, and speech impaired community.
3347 Thank you.
3348 THE CHAIRPERSON: Thank you. Commissioner Shoan will lead the questioning.
3349 COMMISSIONER SHOAN: Thank you very much for your presentation and thank you for being here today.
3350 I have a few questions based on your submission earlier and then, of course, I have the always fun staff questions as well afterwards.
3351 With respect to your May 2013 filing I noted that you urged a capping of the VRS costs to prevent them from escalating out of control. And as you mentioned in your presentation this morning, you also stated in your May 2013 filing that it should be capped at about $30 million per year which was in line with the Mission Consulting Study.
3352 My question, though, for you is the Mission Consulting Study estimated at the $30 million or the $32 million cost based upon a monthly usage of VRS service of about 37 minutes, around that monthly which TELUS noted seemed a little low -- but given the fact that perhaps their estimates were somewhat on the conservative side, can you speak to whether or not $30 million would be adequate to fund such a service?
3353 MS GRIFFIN-MUIR: I recognize or we recognize this service is built on scale just like any network service. But I guess what we were trying to do is find a point where they seem to think that was relatively reasonable and on a certain level you would think with a low number of minutes it might actually have the reverse effect of raising just from a scale perspective.
3354 Also, we were looking at just how what seemed out of control to us the costs in the U.S. had become. So we were trying to find some sort of balance between those two. I can't say we did any real scientific. We were looking at what the recommendations were there, some of the input from Sorenson and trying to balance between those two things.
3355 Again, by having a cap also and at least initially a reasonable cap, it does encourage a little more efficiency.
3356 COMMISSIONER SHOAN: Sure. That's a fair statement.
3357 Just as a point of clarification, you mentioned or MTS mentioned they would support a phased-in implementation of a national VRS service. That phased-in approach would you support the one proposed by the Mission Consulting approach or do you have a different timeline or phased-in implementation approach?
3358 MS GRIFFIN-MUIR: Yeah. I guess, we were looking at a five year -- I think Sorenson had six years or, well, they don't want it phased in but if they were phased in they were looking at a six year time with the costs.
3359 But, yes, we would support that kind of -- if there is a service that would be phased in to get first of all just a sense of what's involved in delivering the service, what kind of demand levels there are, to match that usage pattern with what's actually happening and then to give everybody time to understand how the service works.
3360 COMMISSIONER SHOAN: Absolutely. Certainly for the initial phase in period establishing real demand and allowing for the growth of interpreters would definitely be a key development. So thank you for that.
3361 You stated in your submission that MTS does not believe there is any reason to mandate a basic VRS internet package. The question is why or why not and can you expand further upon that?
3362 MS GRIFFIN-MUIR: Well, I guess, it's not any specific reason other than the availability of internet very broadly and the wide use of internet. So there didn't strike us a need in particular for any kind of specific package for this service.
3363 COMMISSIONER SHOAN: Do you employ any traffic management practices that could potentially affect the quality of service for VRS service?
3364 MS GRIFFIN-MUIR: Well, we have some practices on our wireless service that limits kind of over the month the usage, depending on the service you have.
3365 Yeah, there is a pretty high volume. If, for example, the volume of calling were or usage were similar to what was just described by the previous witness, I don't think there would be any problem with that.
3366 COMMISSIONER SHOAN: Okay. Thank you.
3367 And before I go on to the staff questions, I made note both in your submission and your presentation today that you referenced the use of Skype as a platform in Australia which is certainly an interesting development and definitely an option here depending on who selects the platform which is essentially my question to you.
3368 In terms of platform selection is that the responsibility of a potential third party administrator?
3369 What are your views on who should be selecting the platform and should it be one platform with interoperability or simply one common platform mandated on all potential VRS providers and users?
3370 MS GRIFFIN-MUIR: So our ideal would be one common platform. That would be -- our recommendation was to have a board and that board would include the telecom service providers, interpreters, other stakeholders so that collectively there could be a decision as to what the platform should be, how it would work and obviously it has to be interoperable.
3371 That's why a single platform is ideal. But failing that and a little more complicated, you would have to have some sort of interoperability.
3372 COMMISSIONER SHOAN: Okay.
3373 MS GRIFFIN-MUIR: If there is multiple providers or platforms.
3374 COMMISSIONER SHOAN: Okay, thank you.
3375 Cumulatively, the companies have collected approximately $75 million more than what is -- pardon me -- what it costs MRS for the five-year period from 2008 to 2012. Given your opposition to Sorenson's proposal where surpluses are redirected towards VRS how should these surpluses be addressed?
3376 MS GRIFFIN-MUIR: Well, I think we're talking now about rates that were established, in our case anyway, by the CRTC and reviewed first in 2001 and 2007. So it would be something that at best could be only looked at prospectively.
3377 I guess that depends what decisions are made in terms of funding if there is VRS selected, what decisions should be made in terms of how that would be funded.
3378 COMMISSIONER SHOAN: Okay.
3379 Do you feel whether a review of -- in your view, whether a review of MRS rates be appropriate in the event that the VRS is implemented?
3380 MS GRIFFIN-MUIR: It would again depend on what the plan was to do with those rates. I mean, we would have to look at the rates and the costs and determine whether they fit in with what's happening with MRS and what's happening with VRS.
3381 COMMISSIONER SHOAN: Okay. Thank you.
3382 Carriers have expressed that VRS is outside their area of expertise as has MTS and, therefore, they should not be held responsible for the direct provision of VRS to their customers. They therefore oppose the MRS approach where carriers would assume the responsibility of selecting their VRS provider and managing those contracts.
3383 Given this situation, I have several questions. The first one being, why is the MRS, i.e. the tariffed approach, not optimal for VRS?
3384 MS GRIFFIN-MUIR: Well, the service provided with MRS is something that the telephone company could actually provide with their existing staff as opposed to the VRS. We don't have that kind of -- I mean, there is no interpreters or interpreter community within a telecommunications company per se.
3385 So it seems that it doesn't fit as readily. From operator services to VRS services there is a big jump. Whereas from regular operator services to a TTY-based service, the skills that are employed by the staff in a telecom company could be utilized for that service. That is not the case with VRS.
3386 COMMISSIONER SHOAN: Okay.
3387 MS GRIFFIN-MUIR: I guess there is just one more thing. It is broader than a telecom company as well. Like, it is all telecom service providers and cable providers. Like, it is an internet-based service, so it has a different ramification to it. And I guess even in terms of funding maybe a different formula, as we propose, would be a better way of approaching it.
3388 COMMISSIONER SHOAN: Okay, thank you.
3389 As a general question, what is the difference in managing VRS provided by a third-party provider over managing other operator services provided by third-party operators or providers?
3390 MS GRIFFIN-MUIR: Well, I think the difference is similar distinction in terms of who is involved in that.
3391 So even us, because actually we use TELUS to provide our operator services, we understand where TELUS is managing for us and we have certain obligations with respect to those services that are part of the delivery of a telecommunications service per se, as opposed to a service that has broader ramifications from a social perspective and involves other stakeholders that do not normally interact in the provision of telecommunications service.
3392 I would say that is the largest difference, is just the knowledge of the service. Like, you are managing something you already understand even when you contract it out. Similar to contracting anything out that is precisely related to the delivery of telecommunications services. Because that is the business we are in.
3393 Video relay service is not necessarily a telecommunication service, it is the content that is delivered over a telecommunications facility.
3394 COMMISSIONER SHOAN: Right. So you are saying, given that the nature of the service involves interpretation and a relationship with the deaf and hard of hearing community, that is not necessarily expertise that a telecommunications company would have whether or not they are doing it themselves or subcontracting to a third party?
3395 MS GRIFFIN-MUIR: That is right.
3396 COMMISSIONER SHOAN: Okay. That actually answers my next question, which was going to be how does that type of third-party relationship differ from such a relationship you would have with a third party build out of fibre networks? But you have already addressed that, so thank you.
3397 Again, general question, why should VRS be treated differently than an IP relay service in terms of its structure obligations, obligation to CLECs, things of that nature?
3398 MS GRIFFIN-MUIR: I just want to make sure I understand the question. So are you asking me that if you mandated VRS, should it be everybody is obliged to provide it, including CLECs?
3399 COMMISSIONER SHOAN: I think the question is coming from a place of, right now, delivery of IP relay is really on the LECs, I mean it is on the providers, pardon me, the telcos, the TSPs. VRS I think everyone is recommending, as you have noted, that they don't have the expertise. It should go out. As such, there is a different set of expectations and structures that would flow from that obligation.
3400 And you may have already answered this in terms of the level of skill and expertise, and that may simply be the answer. But for the purposes of flushing out the record a little bit further, if you can address that a little bit further?
3401 MS GRIFFIN-MUIR: Well, basically it is really the level of experience. It isn't that the telco would remove themselves entirely, we are not proposing to absolve ourselves from any involvement.
3402 If the service were implemented, and if it's implemented as we are recommending, there would be a board that the telecom providers would form part of. It is more a question of the type of service it is compared to IP relay service and why it shouldn't be the responsibility of the carrier solely.
3403 COMMISSIONER SHOAN: Okay, thank you.
3404 Are carriers able to absorb the cost of VRS, and why or why not?
3405 MS GRIFFIN-MUIR: Well, with any issue that is really a social issue and in the broader public interest, I mean the question then is if it is deemed to be a broad social issue and if the costs are reasonably administered, distributed and actually capped.
3406 I mean, can we absorb it or not is really not something that we really have control over. I mean, ultimately it is absorbed by our general base of customers just like every class is absorbed. And that is something that, if the CRTC thinks this is a social benefit and in the broad public interest, there would be obviously a requirement for us to absorb the cost in some form or another.
3407 COMMISSIONER SHOAN: Okay, thank you.
3408 So to carry that a step further, what would be the maximum acceptable rate increase for all subscribers to fund VRS? Can you throw out a number?
3409 MS GRIFFIN-MUIR: No, that is a difficult thing to say. Because that is a very individual subscriber. I mean, there are a certain level of charges for a variety of services that either individual subscribers bear or the base of subscribers bear.
3410 COMMISSIONER SHOAN: And as I recall from your submission, don't have the page in front of me, the recommendation was that it be spread out amongst the base. Is that correct?
3411 MS GRIFFIN-MUIR: What we were recommending actually for the cost of this is to make it part -- well, our first recommendation is the general -- the entire population, not just telecommunications customers. But then what we were recommending was the contribution fund.
3412 So we have the fund for a high-cost serving area. It would be adding the cost of this to that fund and spreading it over the base of all services as the per-revenue levy that exists today.
3413 COMMISSIONER SHOAN: Okay. And you are not prepared to give a general range of an acceptable rate?
3414 MS GRIFFIN-MUIR: No, I mean, I think you could look at rates that are out there to support other social benefits and make a determination within that range.
3415 But I couldn't tell you what is an acceptable price increase. I mean, depending on -- well, I am sure if I asked our customers, they would feel no price increase is acceptable.
3416 COMMISSIONER SHOAN: Right, absolutely.
3417 But there is always, given the -- okay, fair enough. That is a fair statement.
3418 So I am just going to push you a little bit further on this because I just want to make sure the record is clear on this. So if I were to say .30 cents, .20 cents, .15 cents? Do any of them sound palatable? Do they all sound ridiculous? What is your perspective? Well, not ridiculous, but unreasonable.
3419 MS GRIFFIN-MUIR: I mean, all of them are within the range of what is today charged for MRS services where certain telecom providers have a charge. So likely not ridiculous.
3420 COMMISSIONER SHOAN: Okay, thank you, I appreciate that.
3421 MTS Allstream submitted that a taskforce consisting of deaf, hard of hearing, and speech impaired, and CRTC representatives should be established to set parameters of service, prepare RFP and choose a VRS provider.
3422 Would this task force have a role beyond establishing parameters, preparing the RFP and selecting a VRS provider?
3423 MS GRIFFIN-MUIR: Well, subsequent to that initial role, there would be an ongoing board of directors that would oversee the -- let's call it management and operation of VRS service.
3424 COMMISSIONER SHOAN: Can you describe a little bit further about the selection process? How would it work? Who would have the final approval of the selection, things of that nature?
3425 MS GRIFFIN-MUIR: You are talking about selection of the vendor themselves?
3426 COMMISSIONER SHOAN: That is right, from the RFP.
3427 MS GRIFFIN-MUIR: Yes, okay.
3428 So there would be a board of directors, as under our proposal, that would be made up of the telecom service providers, the interpreters --
3429 COMMISSIONER SHOAN: Would the board of directors in this scenario be somewhat similar in theory to that presented by Mission Consulting in its report or would it be different --
3430 MS GRIFFIN-MUIR: No, it would be similar. And not -- like today, we have the CCTS that has a board of directors made up of stakeholders --
3431 COMMISSIONER SHOAN: Right.
3432 MS GRIFFIN-MUIR: -- not necessarily the same stakeholders, but the same idea.
3433 COMMISSIONER SHOAN: It is conceptually the same idea?
3434 MS GRIFFIN-MUIR: Yes.
3435 COMMISSIONER SHOAN: Very good. Okay, thank you.
3436 So just to play that out a little bit further, the board of directors of this theoretical entity would issue an RFP, make a decision.
3437 In terms of the next step, once a provider is chosen, just so we understand conceptually how it would work or how it could work, how would the contracts be entered into, how would they be administered? Would a provider be contractually obligated or would they contract with this third-party administrator or this entity? Would they contract with telcos?
3438 What would be the role of the CRTC in that scenario? Would we have oversight? Would we have a more interventionist role? If you could expand upon those issues further?
3439 MS GRIFFIN-MUIR: Well, the contract would be with the entity, and because the telecom providers are part of that board it's through the telecom providers that the CRTC could influence decisions of that entity.
3440 COMMISSIONER SHOAN: So, you're saying the composition of the board would have actual representatives of the TSPs? They wouldn't be independent of the TSP but selected by the TSP?
3441 MS GRIFFIN-MUIR: No, that's right. They would have representatives like the CCTS has representatives.
3442 COMMISSIONER SHOAN: Right. Okay, fair enough. Fair enough. I was simply conceptually drawing a distinction between the Mission consulting report and the CCTS structure. So it's good the distinction was made.
3443 So in terms of this third-party entity, in concept, if it's operating somewhat like a consortium in terms of gathering the funding from the TSPs, presumably it would also be this entity that pays out a VRS provider once the service has been implemented or do you see it happening in another way?
3444 MS GRIFFIN-MUIR: Well, what we're proposing is that the National Contribution Fund be used.
3445 COMMISSIONER SHOAN: The National Contribution Fund.
3446 MS GRIFFIN-MUIR: So, once the cost is identified and agreed to, then the Contribution Fund would be -- and which is already administered --
3447 COMMISSIONER SHOAN: That's right.
3448 MS GRIFFIN-MUIR: -- would pay for the cost of the VRS service.
3449 COMMISSIONER SHOAN: Okay. Okay, thank you.
3450 Two potential models separate from those identified in the Notice of Consultation could be one of the two that I describe as follows.
3451 A hybrid model with obligations still placed on the LECs or some subset by tariff or section 24 condition and subsidization of this service through a centralized fund established under section 46(5) of the Telecommunications Act.
3452 In this model TSPs would be required to contribute to the National Contribution
3453 Fund to pay for VRS. However, some or all LECs would be responsible for provision of the service and would be required to file a tariff with the terms and conditions upon which it will be provided. The fund administrator would provide each LEC with an amount set by the Commission to subsidize the cost of providing this service.
3454 So I think you've made your preferences clear with respect to the model you would like to see, but in terms of fully fleshing out the record, if you can give your thoughts on that potential model.
3455 So, in essence, in this model the LECs would be the ones providing the service and what would be your thoughts on that, based on the draw on the National Contribution Fund?
3456 MS GRIFFIN-MUIR: So the basic difference is the LECs are obliged to provide this service, but the LECs would likely anyway contract with a third party. So that would be the fundamental difference then between what we're proposing, is just have a third party do it.
3457 COMMISSIONER SHOAN: You're saying cut out the middle man?
3458 MS GRIFFIN-MUIR: Right.
3459 COMMISSIONER SHOAN: There wouldn't be any need to have Brighton. Okay. Understood.
3460 MS GRIFFIN-MUIR: Okay.
3461 COMMISSIONER SHOAN: The second model which was not in the Notice of Consultation but we would very much like to get your perspective on is a model in which VRS is funded through a centralized fund to which all TSPs or some subset of TSPs contribute and a third-party VRS provider would be selected through a CISC-like process by a group with representation from industry, organizations representing the deaf and hard of hearing, and interpreter organizations.
3462 The CRTC would then approve or reject the recommendation. LECs would remain ultimately responsible for providing this service and would be compensated from the fund.
3463 Do you have any perspective on that potential model?
3464 MS GRIFFIN-MUIR: It's not really all that different from having an independent administrator.
3465 COMMISSIONER SHOAN: Okay.
3466 MS GRIFFIN-MUIR: I mean the composition of the group of people who would be working on initially developing the requirements of the service and determining what the RFP should include and then selecting the service provider would be the same in both cases. I guess procedurally it might be a little longer process.
3467 COMMISSIONER SHOAN: Okay. Thank you.
3468 So MTS and SaskTel have supported a cap of $30 million. Very quickly, why $30, how could such a cap be implemented, and would a cap be maintained if costs were to change?
3469 MS GRIFFIN-MUIR: Okay. Well, the why $30 million is really kind of the midpoint of the Mission report --
3470 COMMISSIONER SHOAN: Right.
3471 MS GRIFFIN-MUIR: -- the midpoint of that range, and certainly anything in that range is acceptable. I think some of it --
3472 COMMISSIONER SHOAN: The midpoint, by that you mean the $32 and $27, so you selected the $30?
3473 MS GRIFFIN-MUIR: Yeah. We're just --
3474 COMMISSIONER SHOAN: Understood. Okay.
3475 MS GRIFFIN-MUIR: It's not highly scientific.
3476 COMMISSIONER SHOAN: Right. Okay.
3477 MS GRIFFIN-MUIR: And then a lot of it's driven by some of the, what we would call, out-of-control costs at the other end from what's happening in the U.S., so that by having a cap and trying to stay within a cap, it is our view that it produces maybe a more efficient view.
3478 I mean, for example, if you're putting together an RFP, you have a cap there in place. The service provider would then be looking at what the cap would be and determining whether or not they could actually provide service under that kind of cap.
3479 And since that point was provided by an independent study, we thought it's not unreasonable.
3480 COMMISSIONER SHOAN: Right.
3481 MS GRIFFIN-MUIR: If, as your final scenario goes, you find the cost is more or less, obviously you can, on examination of the cost, make some sort of determination as to whether the cap continues to be appropriate.
3482 COMMISSIONER SHOAN: Okay. Thank you very much.
3483 MTS has proposed that VRS funding be included in the existing NCF, the National Contribution Fund, because it would result in lower administration costs presumably in terms of getting this off the ground.
3484 Given the company proposed to make retail Internet revenues subject to VRS contribution, wouldn't lower administration costs of one fund be reduced/offset by using a different definition for VRS eligible revenue than contribution eligible revenue?
3485 MS GRIFFIN-MUIR: I don't think it would be offset. I mean it's a pretty -- we already report that and deduct it. So, for one, you would keep it included and make a determination as to what the revenue base is for VRS versus the high-cost serving area fund. But I mean all that information is already recorded.
3486 COMMISSIONER SHOAN: Okay.
3487 If, as proposed by MTS, the Commission determined that retail Internet revenue -- sorry, my apologies to interpreters, I'm speaking quickly.
3488 If, as proposed by MTS, the Commission determined that retail Internet revenue should not be a deduction for VRS funding, provide the company's views with respect to the deductibility of the Internet-related inter-carrier payments.
3489 MS GRIFFIN-MUIR: Actually, I just want to make sure I understood your question. So you're saying you would not agree to adding the Internet charges?
3490 COMMISSIONER SHOAN: So, I want to make sure that my question is accurate.
3491 Your recommendation was that Internet revenues be included or not included?
3492 MS GRIFFIN-MUIR: Included.
3493 COMMISSIONER SHOAN: Okay. Then my note is incorrect. I apologize.
3494 MS GRIFFIN-MUIR: Okay.
3495 COMMISSIONER SHOAN: I would like to talk a little bit about 9-1-1 and to what extent the existing 9-1-1 network support in terms of direct access to public safety access points and 9-1-1 call-takers would be adaptable/work with a potential VRS service and if you have any views in that regard.
3496 MS GRIFFIN-MUIR: Actually, I don't know the answer to that question. I mean I think there would be certain challenges there too but we didn't look at that.
3497 COMMISSIONER SHOAN: Okay.
3498 Will VRS users have to subscribe to a voice service, an Internet service or both? Why or why not?
3499 You've been very clear in your presentation that it is an Internet service. Other carriers or telcos have been -- or the cable carriers, I should say, were very adamant that this is essentially a voice telephony equivalent service. And certain interveners who have appeared before us indicate that in their jurisdiction they're required to get both services.
3500 So can you provide your perspective on that?
3501 MS GRIFFIN-MUIR: Well, we do believe it's an Internet service and we have suggested the Skype platform which does not require voice service. It's an over-the-top platform.
3502 COMMISSIONER SHOAN: Right. Okay.
3503 So, the FCC has indicated that the VRS weighted average cost for all service providers is approximately $3.39 per minute.
3504 Is there any reason to believe that this cost in Canada is not the same as in the United States, and if so, why?
3505 Incidentally, if you wish to take certain questions as an undertaking to answer later, that is perfectly fine. I recognize that I'm asking you very detailed questions right now.
3506 MS GRIFFIN-MUIR: I mean, certainly we looked at the range of costs and discussed them and the different arguments. And for us, it's hard to get in behind how those things were developed in the first place.
3507 So it's been -- especially because it is a very wide range. Like when you looked at -- even taking into consideration TELUS' -- the cost for their trial, they're in the six range.
3508 And so that was, according to Sorenson, because of the limited trial, limited demand. And we're assuming the FCC number comes from broader availability, larger demand.
3509 So I'm assuming there's some correlation, but even in the questions that Sorenson was asked in terms of that particular question, it was very difficult for us to understand what, exactly, they were getting at. And frankly, I think they're better people to answer what is reasonable, what is not reasonable --
3510 COMMISSIONER SHOAN: Okay.
3511 MS GRIFFIN-MUIR: -- than we are, although, I mean -- they should have to demonstrate why they think it's reasonable, which is less clear in their submissions.
3512 COMMISSIONER SHOAN: Right. And certainly we will be querying Sorenson when they're before us.
3513 I have one last question about education and outreach. How do you think it should be funded and, typically, who do you think should be conducting that outreach and education to the deaf and hard of hearing community if a VRS service is implemented?
3514 MS GRIFFIN-MUIR: So I think we would look at it as in keeping with our proposal, which would have a specific group, it would be through that Board that the way the outreach would be done and all the stakeholders involved would work out a plan for how to inform the deaf, hard of hearing, speech impaired community about the service, how to access the service, et cetera, that that would come through the implementation process.
3515 That would be one more element of it.
3516 COMMISSIONER SHOAN: Okay, that's great.
3517 Those are my questions. Thank you very much.
3518 THE CHAIRPERSON: Vice-Chair Pentefountas.
3519 COMMISSIONER PENTEFOUNTAS: Good morning. I just want to bring you back to your document of the day, and paragraph 4 specifically where you speak about your impression that IP Relay service is not as effective in meeting the needs of the deaf, hard of hearing and speech impaired community.
3520 Some have argued that the TSPs are in part or in whole responsible. How would you respond to that?
3521 I can put some more meat around the bone if you want.
3522 MS GRIFFIN-MUIR: Yes.
3523 COMMISSIONER PENTEFOUNTAS: Great.
3524 Well, the point is the following, that it lacks mobility and, given the fact that there are no apps -- IP Relay apps, you're forced to log on through your web browser and it makes the service very ineffective, as you mentioned yourself.
3525 The point being that TSPs are disinterested, if you will, in producing these apps. They exist internationally, but there's no interest for the creation of this app in Canada.
3526 I'm sort of digging deep into some of the intervenors, and you may not have taken a look at it.
3527 But off the top of your head, what's your sort of reaction to that?
3528 MS GRIFFIN-MUIR: Well, normally we don't -- the service providers don't develop the apps. We utilize apps, but we're not application developers.
3529 I don't know enough about what's available and I don't think my colleagues do, either, to know exactly what the differences are between our IP Relay service and international services or what kind of applications there are -- they are using that makes that service a lot more accessible.
3530 And I'm saying a lot more accessible because that's the impression that I am being given. I'm not sure that it's the case.
3531 COMMISSIONER PENTEFOUNTAS: So it's not the TSP's responsibility or --
3532 MS GRIFFIN-MUIR: Well, it's not what --
3533 COMMISSIONER PENTEFOUNTAS: -- field of endeavour to be in the app --
3534 MS GRIFFIN-MUIR: Right. I would say that --
3535 COMMISSIONER PENTEFOUNTAS: -- creation business.
3536 MS GRIFFIN-MUIR: That's not the business we're in. It's -- we're in the business of telecommunications, so we don't develop the application. We would be using somebody else's application.
3537 COMMISSIONER PENTEFOUNTAS: Okay. On the 911 front, you're the 911 provider -- network provider in Manitoba.
3538 Just to get back to to what extent the existing 911 network support direct access to 911, how conducive is to VRS services as is? Would you be in a position to answer that question?
3539 MS GRIFFIN-MUIR: Well, we -- I mean, the Message Relay Service or the TTY based service, in our view, is accessible.
3540 We also do text to 911. We don't -- sorry; I'm corrected here. We are going to offer it.
3541 So I mean, certainly it's accessible to MRS more, and then text to 911 would give it mobility.
3542 COMMISSIONER PENTEFOUNTAS: Some intervenors would also ask that the 911 network and the 911 call centre have the capability to support a video connection so that they can call directly and speak to someone in sign.
3543 Do you sort of have a sense of the importance, or lack thereof, of that service?
3544 MS GRIFFIN-MUIR: Like a VRS emergency service.
3545 COMMISSIONER PENTEFOUNTAS: Yes.
3546 MS GRIFFIN-MUIR: I can't really speak to the importance. I mean, that would have to come from the community itself.
3547 The ability of the network to support, obviously, exists today, but -- in terms of we can do video here today. But you know, that has to come from the community themselves.
3548 COMMISSIONER PENTEFOUNTAS: And when you mention your $30 million cap, would you see any value in going above and beyond that for the 911 aspect of this service?
3549 MS GRIFFIN-MUIR: Those are -- the value decision is really determined by the broad public interest, so if there is deemed to be value for this in a broader public and social context and the cost of this is whatever it is because it's not factored into the 30 million.
3550 COMMISSIONER PENTEFOUNTAS: Right.
3551 MS GRIFFIN-MUIR: I mean, that would be a determination that you would have to make.
3552 COMMISSIONER PENTEFOUNTAS: Okay. Thank you very much.
3553 THE CHAIRPERSON: Commissioner Simpson.
3554 COMMISSIONER SIMPSON: Good morning. Just a couple of questions going back to a point you raised regarding your position that --calling attention to the Skype technology.
3555 First off, when we heard from TELUS the other day -- and we'll be asking Sorenson for some more information as well -- TELUS, after their involvement in the trial, had chosen to not really offer any opinions as to alternate technologies. And I think it's because of the limitations of the trial, the type of technology being used and the vendor being used.
3556 But I'm curious as to whether you've thought about the prospect that if we were to be agnostic with respect to technology that it might limit the ability to have all experienced vendors of VRS included in the RFP. Have you thought about that?
3557 MS GRIFFIN-MUIR: If you -- I think the way we were looking at it was much more from the more proprietary the technology, the more limitations there are on vendor. And so I mean, we were looking at it in the context of both the cost and getting a multiplicity of choice in terms of vendor, but also influenced by the fact that in Australia -- and we're not pretending to have studied this in any depth.
3558 In Australia, it seemed to work better in the view of their Commission once they moved from proprietary to Skype.
3559 We would have looked at their recommendation, but also just the -- let's call it the limitations of proprietary. So it was more from that perspective that we made that recommendation.
3560 And it's not with any expertise, obviously, or not of our expertise.
3561 COMMISSIONER SIMPSON: Yeah, I understand.
3562 I think I asked that question for a couple of reasons.
3563 There have been some Part 1 submissions so far that have made the statement that VRS as it presently exists is rapidly becoming an out of date technology because there's no longer the need for these proprietary systems and that we should be looking at being able to get ahead of the curve, technologically.
3564 And I guess my question to you as an experienced telecom organization is, from what you know about having to handle multiple devices on your network, should we be considering all technology types at the very outset of a VRS service in Canada?
3565 MS GRIFFIN-MUIR: The way the -- what we think is that we're at a position in the technological evolution and, frankly, the device ecosystem where there are new applications and new uses of existing devices that it makes it very difficult even from our perspective to know whether doing VRS at this time in a traditional way really does make sense.
3566 And that's why we looked to IP Relay, just our experience with IP Relay and what the demand was and even, let's call it, the shift in demand between the time we were looking at it in 2008 and the time the service really got up and running.
3567 And so our concern is really just having the Commission decide that VRS is the way to go and a traditional kind of proprietary platform is the way to implement it, only to find out within a short -- relatively short time period, maybe even as short as the roll-out period, so five years, six years.
3568 That's it not -- that other applications and other uses of video-type technology have overtaken that particular technology.
3569 COMMISSIONER SIMPSON: Right. Just on the -- staying on the start-up phase for a second, we understand your position with respect to ongoing funding for VRS, but what perspective do you have with respect to how we handle the start-up costs?
3570 MS GRIFFIN-MUIR: How we handle external?
3571 COMMISSIONER SIMPSON: Start-up costs.
3572 MS GRIFFIN-MUIR: Oh, start-up.
3573 COMMISSIONER SIMPSON: Yeah.
3574 MS GRIFFIN-MUIR: Well, we would say that would be part of the funding mechanism that we're --
3575 COMMISSIONER SIMPSON: But if it were extraordinary to the ongoing, is there special consideration needed, in your mind? More trials, for example, training, that sort of thing?
3576 And if so, would an extraordinary levy be required?
3577 MS GRIFFIN-MUIR: I guess we'd have to look at the costs over a timeframe because you would expect that they would decline.
3578 I did look at the Sorensons costs. But our expectation would be that there would be a reduction in costs over time.
3579 COMMISSIONER SIMPSON: Yeah.
3580 Back to nomadic VOIP for a second that all carriers in this country are dealing with the issue of location identification, and I would like, for the record, what your position would be regarding whose responsibility it is for ensuring that location identification via users of nomadic VOIP technology -- whose responsibility would it be, the user, the vendor of VRS or the telecom in having accurate information on hand?
3581 MS GRIFFIN-MUIR: Well, today we have certain rules around that in terms of any nomadic service, so most IP voice services, we, the carrier, is obliged to inform the customer of the limitations. And once informed, the customer is responsible.
3582 I don't think that would change.
3583 COMMISSIONER SIMPSON: Status quo rules would apply.
3584 MS GRIFFIN-MUIR: Yeah. Well, if we have that obligation, that obligation can be passed on to whomever we contract with.
3585 COMMISSIONER SIMPSON: But you hadn't really considered whether, because there's an intermediary now between the end user and the network whether that responsibility should shift to the vendor or stay with the user.
3586 MS GRIFFIN-MUIR: Well, I would think that, through the Board -- like in our proposal, it is -- well, the telephone companies of the Board would have that obligation, but it could form part of what the RFP is for the potential vendor, that that obligation could be passed on through the RFP process.
3587 COMMISSIONER SIMPSON: Okay. In your ECR process, you know, your tariff to operators, could they be used in the same way in VRS as how you handle nomadic voice intermediaries, or should the VRS operators have direct access to the PSAP in a 911 situation, or should they rely on your operator services?
3588 MS GRIFFIN-MUIR: I have -- I would -- it seems to me the VRS operator should have it, but I haven't given this a whole lot of thought. It just seems many layers in an emergency if you have to go through several operators to the PSAP.
3589 COMMISSIONER SIMPSON: Right. But you know what, it's something that, I think, is looming large in the back end of this whole process, and I think an undertaking would be a perfect solution to that question, if you don't mind.
3590 MS GRIFFIN-MUIR: Sure.
3591 COMMISSIONER SIMPSON: Thanks.
3592 I think those are all my questions. Thank you very much.
3593 THE CHAIRPERSON: I just have two quick questions.
3594 How many IP Relay connections do you get in a day?
3595 You don't have to give me a precise number, but you could give me, you know, 100, you know, hundreds, thousands, dozens.
3596 MS GRIFFIN-MUIR: I think probably 100, like in that ballpark.
3597 THE CHAIRPERSON: Sorry; I didn't quite hear you.
3598 MS GRIFFIN-MUIR: A hundred.
3599 THE CHAIRPERSON: A hundred?
3600 MS GRIFFIN-MUIR: Yeah. But I could undertake to actually tell you.
3601 THE CHAIRPERSON: One hundred?
3602 If you could undertake it by October 28th.
3603 MS GRIFFIN-MUIR: Certainly.
3604 THE CHAIRPERSON: Would that be okay?
3605 MS GRIFFIN-MUIR: Yeah.
3606 THE CHAIRPERSON: And the other thing is, you made reference in your presentation to the fact that VRS might have somewhat of a best before date on it technologically, that other innovations might take place.
3607 So what are those? What's on the horizon or just over the horizon that makes you think this could have a limited shelf life as the best way to serve the deaf community?
3608 MS GRIFFIN-MUIR: Actually, what we really looked at was the -- looking at a couple of things. Just the fact that in, I believe, it's the TELUS trial, 70 percent of the, let's say, potential base of customers didn't use. They just used point to point.
3609 Also, looking at some of the Sorenson drop which mirrored -- they attributed the drop in, let's say, TTY-based services to the introduction of VRS, but it actually mirrors the kind of drops that we've experienced in Canada, and we don't have VRS.
3610 So it was more in that context that you could see there's a movement to other forms of communication that not only this community, but just people in general have moved towards in terms of communicating.
3611 And then there is or are more applications. Like as the population moves to non-verbal and/or video forms of communication, applications develop around that.
3612 Now, if you're asking me what would that application be, I have no idea.
3613 THE CHAIRPERSON: No. I get a sense of what you're saying.
3614 I actually don't just get a sense. I understand what you're saying in terms of general developments.
3615 Just on that undertaking, could you give that in a -- like a total number and also on a per subscriber basis, like a percentage of your overall use or something like that would be useful?
3616 MS GRIFFIN-MUIR: Yeah.
3617 THE CHAIRPERSON: Thank you very much.
3618 Does legal have any -- oh, sorry. Elizabeth Duncan.
3619 COMMISSIONER DUNCAN: I just have one question. I think everything else -- the other I had has been covered.
3620 You talked about the IP Relay service not being as well utilized as you had first anticipated. And I suppose, in part, that might be because people are using other technologies.
3621 But I think we have heard some complaints about the quality of service. I'm not saying specifically related to your company. But I'm just wondering if that might be part of the problem and if there would be a need, perhaps, to establish some quality standards with respect to that service since it's apparent from the comments we've had that it's going to be an ongoing requirement.
3622 MS GRIFFIN-MUIR: That's a difficult -- I mean, it's difficult for us to answer.
3623 I think, largely, it's the number of customers we have and the -- how we looked at it. To my knowledge, we haven't had complaints about the quality of our service.
3624 COMMISSIONER DUNCAN: Okay. Thank you.
3625 Thanks. That's my question. Thank you.
3626 THE CHAIRPERSON: Thank you.
3627 Legal; anything?
3628 MS POPE: Just one follow-up question on the deduct -- on the internet payments.
3629 On the assumption that retail internet revenue would be included in any kind of calculation of the contribution to a VRS fund, is there any reason to take a different position than the Commission currently does with regard to the deductibility of internet-related inter-carrier payments?
3630 MS GRIFFIN-MUIR: No, I don't see any. I mean, it would flow the exact same way as it flows today, in our view.
3631 MS POPE: Okay, great.
3632 And I understand -- I'm sorry, but I was out of the room. But I understand there was an undertaking?
3633 THE CHAIRPERSON: Yes, you missed it.
3634 MS POPE: So I'm just here to say is the date of next Tuesday, the 29th, an acceptable date for filing that undertaking?
3635 MS GRIFFIN-MUIR: Oh, well, it's better than the date we got.
3636 MS POPE: Oh, okay. So I'll take that back.
3637 THE CHAIRPERSON: So what date did we settle on?
3638 MS GRIFFIN-MUIR: The 29th is good.
3639 THE CHAIRPERSON: Okay. Maybe she'll leave the room more often.
3640 Thank you very much.
3641 We will take a 15-minute break.
--- Upon recessing at 1034
--- Upon resuming at 1054
3642 THE CHAIRPERSON: Order, please.
3643 Madam Secretary.
3644 THE SECRETARY: Thank you. We will now hear the presentation of Ms Tatiana Kamaeva. You have 15 minutes for your presentation. You may begin. Thank you.
3645 MS KAMAEVA (interpreted): Hi. Good morning. My name is Tatiana Kamaeva. I am deaf.
3646 I have moved to a beautiful free country, moved here 15 years ago from -- near Russia. I grew up in a very big, noisy city in Russia, in Moscow. Russian sign language is my first language. I also know Russian, American Sign Language, and I can read and write English. I do rely on the interpreters here for communication. I also know international sign language. Sign language is a beautiful language. We have a very strong deaf culture and communication is comfortable for me when I'm using sign language.
3647 I remember when webcams became the norm and when they were first connected to computers, it was wonderful for me as a deaf person. I was able to use MSN, Skype, Camfrog. I was able to use video to communicate with others across space and time.
3648 I work at the Canada Post Corporation. It's one of the largest companies or corporations in Canada, and I've been working there for many years.
3649 I heard from the BCVRS Committee that we needed to sign petitions to support VRS service in Canada. I brought a petition to my co-workers at Canada Post and had many of them sign in support of VRS service for us. That petition ended up making its way fairly high up in the company. Everybody was in support of having VRS service. There were about 300 people who signed the petition in my area of Canada Post. One thing I noticed was that somebody on the petition had written, "This is the 21st century. I don't understand why we're even still using TTYs." In the U.S. there's a lot of competition for VRS service. I feel like Canada has slipped behind what's the norm in other countries.
3650 We work so hard. I sometimes feel like we're working day and night. I work a full-time job at Canada Post and I'm also a single mother of two beautiful children, both of whom are deaf. My oldest son is 7. My daughter at 5 is hard of hearing. And they're both in a school where they study with other children, not all of whom are deaf. They want to be able to contact their friends. They want to be able to arrange visits. And when the VRS trial was ended, it was a hardship for myself and my children.
3651 Deaf people often don't read and write at the same level that hearing -- or that non-deaf people do. Sign language is the natural mode of communication for us. We're able to talk to one another. And through VRS service, we can talk also to hearing people. I know my mother worries about her grandchildren and wants to be able to contact them. My children have difficulty making friends and connecting with friends without VRS service.
3652 The VRS trial was a really big benefit to myself and my family. Without that, I feel like we don't have the support that we need here in Canada. I thank God for the time that we did have with VRS service. I'm at home with my children. It helps if I don't have to drive to and from different locations to even make appointments. For example, going to a doctor's office or if my children are sick, it's nice to be able to contact somebody online through an interpreter. So many calls that I need to make can be made so much quicker and easier with VRS service.
3653 One time I had to call a Canada Revenue Agency tax centre. I had to use a TTY because I no longer had VRS service. I called the TTY line and nobody answered. It rang several times before I finally got frustrated and hung up. I then called the government in Victoria and experienced the same problem, nobody answering on the TTY line. As a deaf person this is very, very frustrating.
3654 When I call through VRS, I have somebody answering the phone immediately. I've got real-time communication. And when they contact the person who is not deaf that I'm trying to contact, the interpreter can explain how the system works. I at one time had a VRS operator ask me if somebody at their centre had a TTY. The interpreter relayed that they could hear people talking in the company, but without any decision on whether a TTY could be provided to me at that time -- or TTY service could be provided to me at that time. Many people don't know how to use a TTY and that becomes a frustration as well. I experienced that at Canada Post, so many people are confused. It was very frustrating for me when the service was cut.
3655 For me as a deaf person, surviving without VRS service is very difficult. My ex-husband has been looking for work for some time, but it's very frustrating for him because he has no VRS service. He has a passion for cooking. It looks like he was born in a kitchen. He watches the Food Network continuously. He watches Hell's Kitchen, Gordon Ramsey's kitchen. There are so many food programs that he loves. He's worked in restaurants and he's tried finding work here, but it seems like the doors are always closed for him. He can't set up his own business. He can't open up a restaurant because he doesn't have access to interpreters through VRS service. There's no way that he could run a business with only having TTY as access. We also have availability of using text messaging nowadays, but VRS service is the absolute necessity for people who are trying to run a business.
3656 Because my ex-husband doesn't have work, he is not able to support myself and my two children.
3657 I've gone back and forth to Russia fairly often to visit my mom. She's getting old and her health is not as good as it used to be. Seeing what Russia has is mindboggling because since 2008 they have got a new position with a gentleman by the name of Vladimir Baziev(ph), who holds a position in government, it's a paid position, where he is able to advocate on behalf of deaf people. He's visited the United States to see what kind of services are provided there, and has brought this information back to Russia. Russia now has VRS service. They have closed captioning and other technology that is far in advance of what we have here in Canada.
3658 When I'm at home in Russia, there's the ability to see if somebody is phoning because we use the television to communicate. We can switch from television over to a video relay service so that we can experience phone calls in the same way that a person who is not deaf can experience. Airports, hospitals, subways all have access to communication for deaf people.
3659 When I come back here to Canada, I see that we're still struggling for this. It's too long and Canada is too far behind the rest of the world. I think that we need to change the way that we do things in government. I find it odd that Russia, a very poor country, a country that's experienced so much political turmoil, that fought to gain independence from communism, a country with people who struggle daily, I find it funny that they've got a government who supports deaf people by providing the services that we need.
3660 And then when I come back here to Canada, a country with so much providence, I see that our quality of life isn't as good. The quality of life for people who are not deaf in Canada is wonderful, but that's not true for myself and for my other deaf Canadian friends. People who have other disabilities, like individuals who are in wheelchairs, have special accessibility. There are elevators which are larger, ramps, buses with lifts to allow them to have access, but as a deaf person I'm not getting the same type of service, I'm not getting the same type of accessibility, and I wish sometimes that we could transpose the laws that they have now enacted in Russia here to Canada so that I as a deaf Canadian could feel like I've got a life that is equal to that of my non-deaf Canadian friends.
3661 I'd like to feel like I'm equal as a citizen in Canada. We have Jean Day, we have Anti-Bullying Day. Soon we're coming up to a month called Movember, where we recognize people who have fought or are fighting cancer. I wish that we could set up a day where we turned off the radio, we turned the volume off on the TV and everybody learned to live like I do, in a quiet world. I wonder if things would change quickly. I think that laws would change because everybody would have to learn how to communicate in a different way. They would start to realize that text messaging can be limiting, that sign language is the language that is the clearest, the easiest to understand. People would start understanding that as a deaf person I need closed captioning on the TV. If everybody had to live in a deaf world for even a short time, they would start to realize how important sign language is and how necessary VRS service is to deaf Canadians.
3662 I would like to encourage the CRTC to hire somebody to work as an advocate within your corporation. I think it would help. I think that you would have to survey the deaf community less if you had somebody on staff who could gather information and provide that valuable insight. My iPhone is my baby. I use my iPad and my laptop, my MacBook, I use Mac TV because technology has made such a difference for me as a deaf person.
3663 The Mac Store provides free workshops and seminars to people who are deaf. They provide communication access. They have that in Vancouver, Edmonton, Toronto. I think that if we asked for funding from the Ministry of -- in commerce and industry that we could provide a way to support VRS service. I think that we need VRS service in Canada. I think as Canadians we need to be recognized as a leader in providing accessibility to all Canadians. I think that Canada needs to catch up to other countries around the world in the accessibility that they are offering to deaf people and VRS service is one of the ways that Canada can do that. I hope that my dream comes true. I hope that it's realized.
3664 I think that we can work together to find a solution to this. I wish that countries around the world would recognize Canada not just as coming on par with them but as becoming a leader, that our barriers to communication access would be removed so that deaf Canadians could establish businesses of their own.
3665 We need to provide access not just for deaf people but also for hearing -- for non-deaf people to be able to communicate with me and my deaf fellow Canadians. I want Canada VRS service now 24/7. You see me on video today, you see that the system can work, and that it's amazing to be able to save so much time and energy. I don't have to fly to Ottawa. My children, your children are our future.
3666 Thank you so much for allowing me to speak here today. Thank you for listening to our concerns, listening to the concerns of the deaf community. I'm speaking from my heart to you today. Thank you.
3667 THE CHAIRPERSON: Thank you very much. I have a few questions for you and I'm -- what I'm trying to do is determine how you use communication and technology, and how that would be impacted by the introduction of VRS.
3668 So you mentioned that your iPad and your iPhone are your babies. If we had VRS would they still be your babies?
3669 MS KAMAEVA (interpreted): Absolutely. If you had VRS service I would actually be able to use the technology that I have such as my iPhone or my MacBook to communicate.
3670 So the technology would just be enhanced by VRS service. It wouldn't eliminate the need for this technology that I have.
3671 THE CHAIRPERSON: Right. So if -- well, first of all, you participated in the trial and I don't think there were any delays in access in the trial.
3672 MS KAMAEVA (interpreted): Yes.
3673 THE CHAIRPERSON: Did you experience any delays in placing calls during the trial?
3674 MS KAMAEVA (interpreted): VRS service is great. Everything was very smooth. When interpreters needed to be switched off there was somebody else ready to take their place immediately.
3675 My experience with TTY service was horrible in comparison.
3676 THE CHAIRPERSON: Yes.
3677 MS KAMAEVA (interpreted): The wait time is extensive.
3678 THE CHAIRPERSON: I don't think anybody has said anything enthusiastic about TTY for some time.
3679 THE CHAIRPERSON: What I'm trying to get at is if -- what I'm trying to understand is if VRS is introduced in a non-trial basis the issue has been raised as to whether there would be adequate supply of interpreters and that maybe there would be delays in placing calls.
3680 If there was a one or two minute or five minute delay in placing a call would you still want to place the call or would you turn to your iPhone or iPad and just send an email instead?
3681 MS KAMAEVA (interpreted): Are you meaning service overnight or are you meaning during the day, because that's quite different.
3682 THE CHAIRPERSON: Well --
3683 MS KAMAEVA (interpreted): I would be hopeful that if it was an emergency, if I was calling 9-1-1 that I would have access immediately.
3684 THE CHAIRPERSON: I would be hopeful too.
3685 MS KAMAEVA (interpreted): I don't know if the VRS service, the team of interpreters that work there, if they were able to maybe set something up so that if it was an emergency that took priority.
3686 THE CHAIRPERSON: I think that would be one of the challenges.
3687 What I'm trying to get at is you said there is a difference between overnight and daytime. If you were calling -- I don't know. If you were calling your doctor's office to make an appointment and you had to wait two minutes to make that call would you wait two minutes to make the call or would you just send the doctor's office an email looking for an appointment?
3688 MS KAMAEVA (interpreted): I'm just getting clarification.
3689 I think that interpreters that are working for VRS service would be able to, as a team, figure out options or figure out ways around that.
3690 THE CHAIRPERSON: Okay.
3691 MS KAMAEVA (interpreted): And recruiting more interpreters.
3692 THE CHAIRPERSON: Sure. And I understand that. I just -- I'm looking for an answer to the question. Would you think you and other --
3693 MS KAMAEVA (interpreted): Oh, I wouldn't mind waiting a few minutes.
3694 THE CHAIRPERSON: Okay. That's what I was looking for.
3695 MS KAMAEVA (interpreted): Absolutely, that would be fine.
3696 THE CHAIRPERSON: Okay.
3697 How much of your VRS --
3698 MS KAMAEVA (interpreted): Actually, maybe I could talk about that.
3699 I mean, if it was a doctor's office I absolutely don't mind waiting a few minutes to get a connection through to the office through an interpreter. If it was an emergency call I would hope that it could be a little bit faster.
3700 THE CHAIRPERSON: Yes, we all do.
3701 What percentage of your -- when you were using VRS during the trial, how much of it was to hearing -- of the calls would be to hearing people and how much were the calls to deaf people using sign?
3702 MS KAMAEVA (interpreted): Because I have children I would be -- maybe I'm different than others but because I have children who are deaf as a mother I was calling mostly people who were not deaf.
3703 THE CHAIRPERSON: Okay. What time of day did you make the calls mostly?
3704 MS KAMAEVA (interpreted): I usually made my calls during the day because I do work nights.
3705 THE CHAIRPERSON: Okay. If you worked days would you make most of your calls at night or in the evening?
3706 MS KAMAEVA (interpreted): Oh, if I needed to phone somebody I would phone somebody whenever that was necessary. It doesn't matter whether it was during the day or at night.
3707 THE CHAIRPERSON: Okay. One last question from me, anyway.
3708 How much of a difference has technological advancement in terms of the internet and the mobile cellular world made in meeting your communications needs in the last 10 years?
3709 MS KAMAEVA (interpreted): There has been a marked improvement. Communication has become much better. My situation with employment has improved as well because of technology.
3710 THE CHAIRPERSON: Anyone else?
3711 Commissioner Simpson has a question for you. Thank you.
3712 COMMISSIONER SIMPSON: Good morning and welcome to my office in Vancouver. I wish I was there.
3713 COMMISSIONER SIMPSON: I may have missed this during your presentation but were you deaf at birth or did this happen -- your deafness happen later?
3714 MS KAMAEVA (interpreted): I was born deaf.
3715 COMMISSIONER SIMPSON: You mentioned that signing is your primary language but also that you speak Russian and obviously English. Did you -- how did you learn English?
3716 MS KAMAEVA (interpreted): Absolutely.
3717 COMMISSIONER SIMPSON: My question has to do with trying to develop a better understanding of how an individual who uses sign language to communicate can learn another language without the benefit of hearing.
3718 MS KAMAEVA (interpreted): Right. As a deaf person I am very visual. I take all my information in through my eyes.
3719 COMMISSIONER SIMPSON: But I guess my question is specific to how able you are to communicate using text. Is it something that in addition to VRS you still would have a significant reliance on using email or text messaging if VRS was available?
3720 MS KAMAEVA (interpreted): If we had VRS service available it would -- my usage would far surpass what I do on text messaging or via email.
3721 Text messaging and email is sometimes very slow where VRS service is real time. Also, sometimes the communication becomes quite long and drawn out which can become confusing. So it's much better to have real time interpreter communication access.
3722 COMMISSIONER SIMPSON: Have you had any --
3723 MS KAMAEVA (interpreted): And often -- sorry, oftentimes as a non-deaf person they will use text messaging and communication flows quite freely. For a deaf person it can be somewhat more problematic. There is more barriers.
3724 COMMISSIONER SIMPSON: Have you had the opportunity to use a video relay message or video relay service in the past?
3725 MS KAMAEVA (interpreted): Oh, yes. During the year and a half trial, yes.
3726 COMMISSIONER SIMPSON: Oh, so you were part of the TELUS Sorenson trial?
3727 MS KAMAEVA (interpreted): Oh, yes, that's right.
3728 COMMISSIONER SIMPSON: And what is your opinion regarding the importance of the Commission considering our recommendation that more than just a proprietary system be available immediately if VRS is applied in Canada?
3729 I'm thinking with respect to mobile devices. Is it something that is somewhat important to you or very important?
3730 MS KAMAEVA (interpreted): The interpreter is just getting clarification here.
3731 Are you talking about private business for the interpreter?
3732 COMMISSIONER SIMPSON: No. I'm asking --
3733 MS KAMAEVA (interpreted): Can you reframe?
3734 COMMISSIONER SIMPSON: Is the use of other mobile devices in VRS important enough to make sure that they are also available in a VRS service in Canada, not just a system that is available at home or at your office?
3735 MS KAMAEVA (interpreted): It would be much better if I was able to get access to VRS service through technologies such as my iPhone. I have my iPhone with me all day and all night. So it's one of the best ways to access VRS service through technology.
3736 I also usually have my iPad with me. I also use my my MacBook a lot. It would be great to have more than just the system that's provided or has been provided.
3737 COMMISSIONER SIMPSON: My last question: Have you ever used VRS using technologies such as Skype or a mobile phone?
3738 MS KAMAEVA (interpreted): No, because I'm Canadian there is no service available. If I was in the U.S. I would be able to access service through my iPhone or my MacBook.
3739 Travelling in the States I've managed to connect through interpreters a few times because I've got some deaf friends down there and so you can get access that way. But as a Canadian I'm barred from using U.S. services. So I haven't been able to use my technology.
3740 There is face time available on iPhone and other Mac products so I can use face time to contact other deaf friends of mine. But non-deaf people I can't access right now.
3741 COMMISSIONER SIMPSON: Was the quality of the service you used using your -- I presume your iPhone -- satisfactory? Were there any difficulties you experienced in communicating with a smaller device?
3742 MS KAMAEVA (interpreted): Oh, there's no communication problems. It's fast and clear all the time that I have used it.
3743 COMMISSIONER SIMPSON: Okay. Thank you very much.
3744 MS KAMAEVA (interpreted): The iPad is a little bit -- the iPad is a little bit bigger than my iPhone so the screen -- obviously it's a 7-inch screen so it's a little bit bigger, a little bit easier to see. But the iPhone is fine.
3745 COMMISSIONER SIMPSON: Thank you very much.
3746 MS KAMAEVA (interpreted): I think that deaf individuals if we had access to VRS service through other technology like iPads and whatnot that there would be probably more purchased.
3747 THE CHAIRPERSON: Thank you very much. That concludes our questions. Please enjoy the rest of the morning in Vancouver.
3748 THE SECRETARY: I will now ask Bell Aliant Regional Communications, Limited Partnership on behalf of itself and DMTS, KMTS, Northern Tel Limited Partnership and Télébec Limited Partnership, Bell Canada, Bell Mobility and Northwestel Inc. to come to the presentation table.
3749 THE SECRETARY: Please introduce yourself and your colleagues and you have 20 minutes for your presentation.
3750 MR. DANIELS: Thank you, Madam Secretary and Commissioners.
3751 THE CHAIRPERSON: Just a moment. Madam Secretary, we still have the video feed from Vancouver on the screen and it's mildly distracting.
3752 THE CHAIRPERSON: It's gone.
3753 MR. DANIELS: And here I am.
3754 Thank you, Madam Secretary and Commissioners. I am Jonathan Daniels, Vice-President, Regulatory Law at Bell Canada.
3755 With me to my left is Bill Abbott, Senior Counsel and Bell Privacy Ombudsman;
3756 - To Bill's left is Cindy Jones-Sherk, Manager of Accessibility at Bell Residential Services;
3757 - And to my right is Suzanne Morin, General Counsel, Regulatory and Privacy Chief at Bell Aliant.
3758 It is clear from the thousands of comments submitted by deaf and hard of hearing individuals and groups that VRS has the potential to significantly improve the personal, social, and employment-related communications of Canadians.
3759 Having read the record of this proceeding, and sat here and heard what you have heard, we have no doubt that you will reach the same conclusion that we have reached. It is now time to move forward with the implementation of VRS in Canada.
3760 One might ask, what has changed from the last time we discussed this issue? Five years ago, the Commission conducted a proceeding that examined, among other issues, whether VRS should be implemented in Canada.
3761 The need for VRS was articulated then, though perhaps not with the same force and eloquence as it has been articulated this week. But the Commission was in no position to order VRS at that time because there was far too much unknown and too many uncertainties.
3762 A lot has happened since. TELUS has completed its trial. In addition, we now also have the benefit of Mission's feasibility study which provides an answer to the core question of how to implement VRS in Canada.
3763 We, at Bell, worked with accessibility groups in a collaborative and iterative process that began with the creation of the RFP and selection of Mission Consulting and continued to the final draft of the Mission Report, which laid out the feasibility of a VRS service in the Canadian context.
3764 Despite the way it is sometimes referred to for convenience in the record, the Mission Report is just that, a report from Mission Consulting and not from Bell Canada. We and all the other groups that were involved recognized that it was essential that Mission be independent. Indeed, we do not agree with all of Mission's recommendations, although we do agree with almost all of them.
3765 Mission conducted extensive research and outlined numerous details relevant to VRS but there are still some things we don't know. Nonetheless, as we will explain, that does not mean we cannot move forward. We can and we should. We believe the Mission Report lays out the road map of how to do just that. But first it helps to take stock of what it is that we know and what we don't know.
3766 So what do we know?
3767 First, the record clearly demonstrates that VRS is needed. It should be available in both ASL and LSQ and provided free to its users.
3768 Second, we note that everyone agrees that the accessibility groups desire and need to be at the table.
3769 Finally, we do not have enough interpreters to launch VRS at full deployment in either ASL or LSQ without completely undermining the interpreter services used in those communities today.
3770 Yesterday we heard from AVLIC that they have 700 members, although there are more interpreters in the total market. Mission estimates the existing pool of interpreters to be roughly 800, with over 200 of them already working for American VRS providers. Mission also estimates that it would take 588 interpreters to provide 24/7 service in ASL and LSQ to a little over 15,000 users.
3771 Some parties have criticized Mission's estimate of the number of users and average minutes per user per month as being too little. As such, if anything, Mission's estimate of 588 interpreters may be too low. How can we expect to launch a service that takes at least 588 interpreters when there is only a total pool of 800 interpreters, 200 of whom are already working for American VAS providers?
3772 In fact, we already heard from some parties that there are not enough interpreters today. If a deaf or hard of hearing person has to wait two weeks to get an interpreter for an appointment that does not sound like an oversupply.
3773 To us, the math is clear. There are simply not enough interpreters. With the six existing interpreter training programs being full, this problem will not be solved unless we tackle it at the source, by funding the entities that train interpreters to allow them to expand their capacity, but only as initial grants tied to directly supporting the implementation of VRS.
3774 Now, I appreciate right now I am slipping into advocacy in a section which is supposed to be limited to agreed facts, but for us this stark reality has to inform the decision on how we collectively proceed.
3775 We share the sentiments of those who do not want the interpreter shortage to become a reason not to proceed with VRS or to delay its implementation. It is this reality that underlies the Mission recommendations. This is what they've been working on and figuring out for the last five years.
3776 And it is also for this reason, we believe, that the accessibility groups that did work with Mission on the report, support their conclusions.
3778 MME MORIN : Même si maintenant nous avons tellement plus de connaissances au sujet du SRV que la dernière fois que nous étions ici devant la Commission en 2008, il demeure encore plusieurs inconnus. Seulement une expérience plus pratique et approfondie pourra éventuellement apporter la certitude qui nous est nécessaire.
3779 Le coût total d'offrir le SRV au Canada est un inconnu de toute importance. Les trois variables qui détermineront le coût éventuel et total d'offrir le SRV sont :
3780 i) dans un premier temps, le nombre d'utilisateurs (de 15,345 à 25,000);
3781 ii) le nombre moyen de minutes d'interprétation de SRV par utilisateur (nous avons vu de 37 à 107 minutes); et
3782 iii) troisièmement, le coût par minute d'interprétation de SRV (de 3,49 dollars à 5,94 dollars).
3783 Différentes combinaisons de ces variables sont en effet responsables du fait qu'il y a une différence de presque 300 pour cent entre l'estimation la plus basse et celle qui est la plus haute. La réalité est telle que nous ne pouvons savoir le coût d'offrir le service de relais vidéo avec aucune certitude.
3784 Nous sommes aussi dans l'impossibilité de savoir à ce stade le temps nécessaire pour se rendre au déploiement complet du SRV. Le déploiement complet dépend dorénavant d'une source adéquate d'interprètes pour combler la demande du SRV sans nuire aux services communautaires d'interprétation. Nous sommes tous d'accord qu'il est nécessaire d'augmenter la capacité afin de supporter le déploiement complet de SRV au Canada, mais nous ne saurions jamais combien de temps ça nous prendra à moins que nous démarrions le processus.
3785 Un autre inconnu soulevé par plusieurs partis, y inclus la Commission, est la question, l'importante question à savoir comment le SRV fournira le relais des appels d'urgence aux centres 9-1-1. C'est un défi qui soulève des questions techniques et complexes, mais ces défis ne sont pas uniques au SRV, et qui ne peuvent être résolues facilement. Même si le défi éventuellement n'est pas lui-même insurmontable, nous ne savons pas encore la réponse exacte.
3787 MR. ABBOTT: Good morning, Commissioners.
3788 I want to turn now to the position we take in light of the things we know and we don't know.
3789 The Commission listed in the Notice of Consultation two basic models for funding and administering VRS: the "MRS" model and the "central fund" model. We will not repeat ail the reasons others have given for rejecting the MRS model but note in addition that it would exacerbate the existing interpreter shortage.
3790 We, like almost everyone else, endorse the "central fund" model. The existing processes associated with the National Contribution Fund could be leveraged to support the collection of funds for VRS with limited additional administrative burden.
3791 In our view, the contributions collected should be based on all Canadian telecommunications service revenues, including Internet revenues, which makes sense when you consider how VRS will be provided. All of the information required to collect the funds on this basis is already being reported to the Commission and could easily be used for this purpose.
3792 These funds would be used by an independent VRS Administrator to provide VRS across Canada. The VRS Administrator would be overseen by representatives from the deaf and hard of hearing user groups, telecommunications service providers and individuals that are independent from any stakeholder group.
3793 The VRS Administrator would have greater expertise and be more efficient and accountable than either a system comprised of a patchwork of individual companies under the MRS model or one that simply outsources VRS in Canada to an existing provider.
3794 Over the course of the week, the Commission has floated two other hybrid models. These hybrid models should also be rejected. We don't see how these models offer better solutions than the "independent VRS Administrator" model. They don't solve the problem of the interpreter shortage and they will likely raise the overall cost of the service, and we are happy to expand on this in questioning.
3795 Almost universally stakeholders before you have supported a single technology platform to be used by both VRS users and service providers. Unlike TELUS, we believe this single platform should be licensed to, or even owned by, the Administrator, separately from the actual provider or providers of VRS interpreting services. This would avoid locking in a potentially higher-cost provider and ensure reliable reporting to the Administrator.
3796 While the Commission has the jurisdiction to mandate VRS and to establish a contribution fund for VRS, it must do so subject to the policy direction and the policy objectives set out in section 7 of the Telecommunications Act, including the proportionality test we discussed in our written submissions.
3797 In our view, the primary effect of the proportionality test is simply to prohibit an approach that places no limit on costs. The Telecommunications Act and the policy direction require that the funds collected to support VRS at any given time be capped at an amount the Commission has determined to be proportionate to the benefits expected to be achieved.
3799 MR. DANIELS: Given what we know and what we don't know, how do we get started? Based on the Mission report, we are proposing a concrete three-phase implementation process designed to quickly and efficiently make available a full-scale high-quality VRS service in Canada.
3800 The three phases are:
3801 - Phase A: Establishing the VRS Administrator.
3802 In this phase an independent VRS Administrator would be established with user groups, telecommunications service providers and independent experts in governance and administration all having a role. One of the first jobs of the VRS Administrator would be to run an RFP process to acquire the technology platform to be used in providing VRS. We believe this phase can be completed in 2015.
3803 - Phase B: This is when VRS is launched, we build capacity and further research is conducted.
3804 Working with interpreter training programs and agencies, in this phase the VRS Administrator oversees the rollout of VRS services to users, the expansion of the pool of interpreters to support further expansion of VRS and additional research to improve VRS for users.
3805 What UQAM/SIVET has proposed in their submission we believe is an example of the work that would be done in this phase. As we understand it, UQAM/SIVET has not proposed a separate model but rather provided a good example of exactly what Mission anticipated during Phase B. We would expect to see other interpreter training programs and agencies who also participated in the development of the Mission report undertake similar proposals.
3806 - Phase C: Ongoing VRS.
3807 Based on what it learns in Phase B and on responses to RFPs, the VRS Administrator would select and oversee the ongoing provider or providers of VRS in Canada.
3808 Key to this approach is Commission approval between each of these phases.
3809 Now, we set this all out, to simplify this, in a one-page diagram. We've actually attached it if you flip ahead to page 11, which I'm happy to take you through in questioning to basically explain what we think can be done.
3810 So what can you do here and now as an outcome of this proceeding?
3811 You can order the implementation of Phase A, and let's be concrete about this. Based on Mission's estimated cost of $5.3 million for Phase A, you can kickstart this process by approving in your decision funding from a central fund of $1 million in 2014 and $4.3 million in 2015 to launch Phase A.
3812 We would like to thank the interpreters and the technical teams for the excellent work they are doing here. We certainly would not be able to participate effectively without you.
3813 Finally, thank you, Commissioners, for giving us the opportunity to take part in this important proceeding. We look forward to answering your questions.
3814 THE CHAIRPERSON: Thank you.
3815 Commissioner Duncan will begin.
3816 COMMISSIONER DUNCAN: Good morning.
3817 I should start off by saying that there's many questions and of course we're very anxious to hear your views, so I'll try to be concise.
3818 I think that given this document that you've given us and the offer to go through it, maybe it would be worthwhile to do that first and that may address some of the questions or at least give us a good start. So if you wouldn't mind, that would be great.
3819 MR. DANIELS: We were hoping you would say that.
3820 Okay, so I am turning for -- we were following this, this is Appendix A, page 11 of our document. What we have tried to do here is to graphically set out -- this is based on, although Mission doesn't use the exact terminology, Mission talks of two phases, but then they have this initial setup before the two phases.
3821 And we sort of thought to make it concrete we change the nomenclature to Phase A, B and C, and put the years on it so that you can exactly -- like, considering we are looking at a -- we are here in the end of October or middle of October for a proceeding, how does this actually happen in practice? So obviously, we are at that first step there in the CRTC proceeding.
3822 If you go and look at what Mission suggested, in the first setup phase what you would do is you would setup -- we need to setup the VRS administrator, that is the board of directors that everyone has been talking about, or not everyone, but many parties have been advocating. So to do that --
3823 THE CHAIRPERSON: I hate to interrupt, but --
3824 MR. DANIELS: Yes?
3825 THE CHAIRPERSON: -- who is doing that?
3826 MR. DANIELS: What we are suggesting is that you direct the TSPs to work with the accessibility groups, give us a timeline to do it. We will get it done.
3827 THE CHAIRPERSON: Through a current interconnection working group or through a new..?
3828 MR. DANIELS: So do we use CISC is I think that question?
3829 THE CHAIRPERSON: Yes.
3830 MR. DANIELS: We are not opposed to CISC, we don't think you need to. We didn't use CISC for CCTS, we didn't use it for the BAF --
3831 THE CHAIRPERSON: Okay. Just establish the group and..?
3832 MR. DANIELS: Just give us the direction, the TSPs --
3833 THE CHAIRPERSON: Okay, thank you.
3834 MR. DANIELS: -- and we will do it, collectively.
3835 THE CHAIRPERSON: I won't interrupt anymore.
3836 MR. DANIELS: And when I say TSPs, it is not that we would do it without the accessibility groups. We are busying telling you all week, us and the other TSPs, what we don't know, we don't have expertise in. We have expertise in setting up these groups. We have done a lot of them recently. And we have got a blueprint, we know what lawyers to call.
3837 And it takes time. And each one is complicated. I don't want to underestimate it. And some of the questions that I think you will be asking me in a few minutes will get into a little bit of the detail of how we see that.
3838 So it is not a boiler plate issue, it takes time. But we do know how to do this and we are prepared to go ahead and commit. I think collectively, I think the TSPs would be interested to working together.
3839 So that would be drafting, incorporating the documents, setting up the board, an interim board, then you have an election for an ultimate board, representatives of TSPs and accessibility groups, finding independent commissioners. Again -- commissioners, independent directors. We have five independent commissioners.
3840 So that initial phase we think could be done fully in 2014 including, I am giving an estimate that your decision comes out in Q1, towards the end of Q1. I am using calendar year, not CRTC year. In Q1, and that's why we are suggesting that to do that initial phase you probably need a million dollars, probably even less.
3841 But a million dollars would certainly allow -- because it is going to be more expensive than any other process. We haven't had interpreters in the process of setting up the documents and so on. So it is going to take a little bit longer to work with all of the groups and get their participation, and so we think a million dollars could do that.
3842 And then once the board is established it gets to work by putting out two different things, or actually I should say three different things. There are two RFPs that put out according to Mission; one is for the platform, and another is for the database.
3843 Again, I am going a little fast here and I would be happy to slow down if you want an explanation of that they have in mind for the database and the platform. There is I think a little bit of confusion about that. But if I now just give you an overview and then we can come back. With your permission, that is how I propose to proceed.
3844 So the platform, the database. And then the other thing it would do is it would run RFI, not RFPs, requests for proposals, but RFIs, requests for information. Which would basically say, go to the interpreter of agencies and tell me how much do you think you can do now, at what cost, and what would it take to expand your capacity? Give us a sense.
3845 And that is where we are saying, and I know in the record to give you what we think would that look like, what an example of that would look like, that is the UQAM/SIVET proposal. They have come back with dollar figures, they have come back with how many seats they need. They have said this is what it would take to provide service in their area.
3846 And that is why we didn't really see it as another model. We see this as an example of the kind of things that all six interpretative agencies and other groups may do and provide to come back over -- I shouldn't say interpretative agency, I should say interpreter training over it.
3847 But at the same time, part of that would be growing the interpreter base. This is what it would take us to be able to hire more teachers to train more people and how long it would take. We will setup the process, we will do it.
3848 And then when we have all that collective information, we come back to the CRTC and say, now CRTC, for the next step we need X millions of dollars over the next four years. It is going to cost this amount, please approve it.
3849 We have a real sense of what it would cost to do that next phase. CRTC, please approve the entire board of directors, the structure, the constituting documents, everything like that just the same way you did CCTS. So we will be back in two years.
3850 I think probably, you know, it could be an easier process that is more, you know, I don't think there will be much controversy, but there would be buy-in from the CRTC to make sure that you are comfortable and that we are on the right track.
3851 Following that, we get to work. The board of directors is going to give out the money and VRS has started to offer in Canada, just as Mission says. It is not going to be 24/7 in it, but it could be somewhere in some places? Maybe. It really depends what people offer.
3852 If people can come forward and say this is what we can do, this is what we can handle, this is what we need, and the board says that makes sense, they will give them the money and we will see what kind of service we can get over the years.
3853 But it won't be just limited to getting the service. It will also be about training interpreters, more interpreters, by expanding the programs themselves. We need to get a bigger base, and we are going to help fund that under this proposal we are at least putting forward.
3854 And following that, at the end of that, we are back at the CRTC again and say, now it is time for a more permanent solution. What is the long-term goal at the end of this? This is when we go to probably 24/7, don't know for sure, got to make sure the interpreters are out there. But assuming that they are and we have grown the base, come back with proposals with actual dollar figures.
3855 At that point I would think that the consortium would run RFPs and come up and say, is it going to be multiple providers, is it going to be a single provider? I don't know. We don't have a position on that. But they would come back to you with a real dollar and say, it is time to approve it. And we will have real money and be able to know what it will cost to get this thing and keep it permanently.
3856 And so that is really our three-phase step. And I wanted to take the time to look through, because -- and I guess the whole point of our opening statement was to say, there is so much you don't know. I don't know how in this proceeding this Commission could come out with the standards for providing VRS. I don't know how we could go and just say, go do it.
3857 There is so much we don't know. But it doesn't mean that we can't get going. And we think, and that is why we have been working very closely with Mission with a goal, how do we make this and bring this to reality in a way that works for everybody?
3858 And that is what we are trying to do here. And we tried to put it down in a -- hopefully a simple page. I realize there is a lot on there.
3859 So that is my long spiel. I am breaking your request to be succinct, but...
3860 COMMISSIONER DUNCAN: That is okay, I think it is very important.
3861 On the reverse, on Appendix B, these are just -- maybe you can just explain quickly at a glance what..?
3862 MR. DANIELS: So Appendix B is just -- we put it there in anticipation of a question from any one of you.
3863 COMMISSIONER DUNCAN: Okay.
3864 MR. DANIELS: It is saying what are the costs and so on?
3865 COMMISSIONER DUNCAN: Okay. So we can wait then to get to that.
3866 MR. DANIELS: But if you want, we can wait. But yes, that is what that relates to.
3867 COMMISSIONER DUNCAN: Okay. So what I propose to do then is go through the questions I have, which I indicated were many, and some others that we will have as a result of your presentation.
3868 And I invite you, and I am sure you would anyway, bring us back to this, if that helps in answering the question. So just to sort of keep the order in which I prepared.
3869 So first of all, you don't agree that the MRS approach is optimal for VRS. And you have made the point that applying the MRS approach to VRS is asymmetrical and, hence, contrary to the policy direction.
3870 So we would just appreciate if you could elaborate more on the nature of the asymmetry that you are referring to.
3871 MR. DANIELS: So the policy direction that the CRTC has says, if you are talking about a regulatory measure that is not of an economic nature to the greatest extent possible or implemented in a symmetrical and competitively neutral manner. So we are picking up on those requirements for symmetry.
3872 The reason we don't think MRS is symmetrical is because it imposes a disproportionate share, first, of the cost on whatever local providers actually have deaf customers who actually sign up.
3873 The way the system works today is that there is a levy of .13 cents for every user. But the actual cost is borne by the TSP to the extent that they have deaf users who actually use their service.
3874 So you can have one company with virtually no deaf customers, and therefore not getting any expense, and other companies that have all the deaf users, getting the expense. There is a disconnection that exists today in the MRS model.
3875 COMMISSIONER DUNCAN: But you would have to incur a certain amount of costs. I would presume everybody would have to incur a base cost just to have the system in place, whether you get one user or two or 2,000.
3876 MR. DANIELS: Not necessarily. It depends if you contract it out or not. Most providers of MRS, not all, most of them -- sorry most LECs, not all, would go to the ILEC to provide the service.
3877 And so, for example, we provide Bell's message relay service or Bell relay service and we provide it to lots of the other CLECs come and buy that service from us, not all. Some decide to use other providers, it is up to them to decide how to do it.
3878 And if they found that they have very low use, they may want to find someone else who charges them per minute. We charge how many customers they have, because that is what we are required to do.
3879 So we are required by our tariff for every single not deaf user, but every single customer you have we have a wholesale rate, and I believe it is .15 cents, right? For .15 cents so, you know, if a CLEC wants to provide -- doesn't want to do MRS themselves, and most of them don't, they can buy -- under our tariff they tell us how many customers, not deaf customers, but total customers they have and they pay us .15 cents.
3880 If they find that they have virtually no use on that of actual customers, they will maybe want to go to someone else where they pay per minute because they don't have to pay all of that.
3881 And I have lost you hear I can see.
3882 COMMISSIONER DUNCAN: Well, I am just thinking that well, you know, it is kind of a business decision. I don't know how the system is actually, no idea.
3883 MR. DANIELS: It is a business decision for them, and that is the right business decision. But the system as a whole has a disconnection. And so between the actual expense of providing the service and the use of the service --
3884 COMMISSIONER DUNCAN: Okay. Just so that I can just repeat. Then what you are saying, that in your instance your expense is based on every subscriber you have, user or not.
3885 And in the other instance, they could charge just based on use?
3886 MR. DANIELS: In our case our revenue is collected based on every subscriber we have. Our expense is what people actually use to service on the MRS. For example, like the actual deaf use, the deaf of hard of hearing use of the service.
3887 Okay, maybe I can get Cindy to explain this better.
3888 MS JONES-SHERK: Sorry. The comment I would like to make, so to build on Jonathan's point, in the case of example IP Relay, regardless of the forecasted amount of users that may or may not use the service on Bell Canada or say on Bell Canada's obligation, which was to serve retail customers, business customers, and also offer wholesale obligation.
3889 So regardless of actually any wholesale customers using that service or one person who needed to use IP Relay, we had to build the whole infrastructure at a fairly significant cost, which the Commission has in front of them as part of the deferral account.
3890 So that is the investment Bell Canada had to make. I'm not sure of the other companies' investment on whole to serve all their individual customers. So regardless of whether they have one or in MTS's cases that they said is a lower number of users.
3891 So the MRS just proves to be particularly very inefficient in the start-up costs to serve a certain subscriber base. That is the point I wanted to make.
3892 COMMISSIONER DUNCAN: Go ahead
3893 MR. DANIELS: So we have gone down sort of because, as Bell, sometimes we put things legalistically, point to the policy direction, you let off by symmetrical.
3894 This is a social obligation, there is no business case overall in terms of -- as we look at VRS, 15,000 users, it is not business case, this is a social obligation. And everyone is unified in saying let's share that equally.
3895 And there is so many different -- beyond just the symmetrical nature and the legalistic argument there, there is so many different reasons why the MRS model is the wrong model for VRS. Primarily, for example, it is what I was talking about before. We need to build a model that is designed around building interpreter capacity and has all the stakeholders in control of all of the various different issues.
3896 The way MRS and IPRS works, you give it to the LECS, you say go do it, you actually say to us, Bell Canada, put up a wholesale tariff so others don't have to do it and they can buy it from you. And then we go and we setup.
3897 And, yes, we do listen to our users. I don't want to say, but we are talking about a chance to do something right from the beginning, taking a model that says there is a much better way to do this.
3898 Let's get everyone together, give them a say, setup a board of directors, and especially -- and this is the thing that I worry personally about -- is if we jump to an MRS-type solution, yes, we can contract it out, yes, we can get going, but at what cost to the deaf community they will have VRS?
3899 But if we are just meeting our obligation, we will do that in a way that by contracting out to someone who just hires interpreters, not worrying about the impact on the rest of the community.
3900 What we are trying to do is put in the social obligation into not just imposing it, but how the whole service is rolled out. That is what our -- I was going to use the pun Mission, that is what Mission report is all about, is trying to find a way to do it.
3901 And the MRS model is not that route, because the MRS model says, go do it Bell, go set it up on your own. And, Bell, we know you probably -- you have no expertise, no problem, just send it out to -- go hire one of the American providers, bring them into Canada, let them use the interpreters. We will do that. We will meet our obligation. There is no doubt we will meet our obligation.
3902 But who is going to stop and say, well, what is going on in the communities? How do we do this? Who is going to do the balance? There is no room for that. Let's setup a model that does it; builds it up in the right way and get service that can sustain itself in Canada.
3903 COMMISSIONER DUNCAN: Okay. I appreciate that you very strongly have a view on this and that you have obviously given it considerable thought. But just so that we have a full record so that we can make the best decision possible, and indeed it might mirror yours, but let's continue on then.
3904 So from the asymmetry point of view that discussion, what you also I think mentioned, the funding was not asymmetrical either? Is that another point that you had that..?
3905 MR. DANIELS: The funding, I mean, it all depends on how -- the exact nature of the MRS, if you adopt the MRS model to be setup.
3906 But clearly, we think that using percentage of revenues, which means if I have a higher revenue, like a business, they are paying a higher portion of it. If you do MRS, you turn it all and they are looking at the amount of subscribers.
3907 I noticed that the other day. The cable companies talked about -- worked out a fee of total households in Canada and gave you just sort of an estimate. But of course it is not every household.
3908 If you go with the percentage of revenue, you are going to have enterprise customers paying a much larger share. They aren't counted as a household. The Bank of Nova Scotia is not a household. But yet their portion, because it would be done by percentage of revenue, that is the more equitable way to share the cost, the entire base.
3909 COMMISSIONER DUNCAN: Okay. And so was that the essence of your argument, that the funding would be asymmetrical?
3910 MR. DANIELS: Yes, as well as the earlier point, which I had a hard time conveying to you, but...
3911 COMMISSIONER DUNCAN: That is okay. Well, somebody smart will figure it out. That is okay, I am following it I think.
3912 I am just wondering, do you agree though that VRS is equivalent to voice telephony for sign language users?
3913 MR. DANIELS: Yes, I do.
3914 COMMISSIONER DUNCAN: Equivalent to voice, okay.
3915 And I want to talk a bit about -- there has been discussion previously, I am sure you are prepared for this, but the $75 million that has been accumulated in surpluses since the introduction of MRS over the last five years, these surpluses will continue to accumulate on an annual basis.
3916 And we are just wondering how would you see those surpluses being handled? Would it be appropriate to use them to offset your company costs or to pool them together, all LECs pool them together and service providers, to reduce VRS costs as a total?
3917 MR. DANIELS: I guess the first thing is we don't really see it as a surplus.
3918 But I am going to take your point in the way, we have a charge for service and some providers have charges for service. So just to explain, even like Bell Canada, we have a .13 cents, right --
3919 MS JONES-SHERK: Residential.
3920 MR. DANIELS: -- .13 cents for a residential charge on a residential bill. For the service Bell Aliant out east, does not have any charge whatsoever.
3921 So when we start talking about the surplus, it depends how you are looking -- and that really gets to my issue first and foremost. Which is let's understand, like I think you heard cable yesterday, there was five companies here and one of the five actually had a specific charge, which was Rogers, and the others didn't.
3922 So if we look out east, and I'm choosing out east partly because Bell Aliant doesn't charge, so it is easier to choose an example where we don't charge. But if you look out east, Rogers has a charge in News Brunswick where they provide service of .19 cents for MRS.
3923 Now, their total cost for a phone there is $24.22 if you are just taking a standalone service. So there is always bundles, there is prices, there is discounts. I am just trying to give you a base mark comparison.
3924 You look at EastLink, EastLink does not have an explicit charge for MRS, and their total charge is $23.50.
3925 Now coming to Bell Aliant, in the four provinces their standalone prices ranges for standalone service from $30.05 to $30.17.
3926 So who has a surplus here? What surplus are we talking about? Because Bell Aliant doesn't have a charge, but yet to the retail customer charges more money than Rogers does, which has a .19 cent charge.
3927 And that is my I guess fundamental confusion about this discussion that has been going on, some have it, some don't. What is the impact? The impact is the retail customer is going to look at what the total amount they are paying and they are going to make their decision based on what they are paying.
3928 And I think this MRS issue, in some ways in terms of a specific levy and looking for it, is ignoring the realities of that it is either built in the price or you split it out. And if you don't build it into the price -- if it is built into the price, how do you determine if there is a surplus?
3929 And are we going to penalize Rogers by saying they have a bigger surplus? I am just making it up. Let's say their cost is .10 cents, we are going to penalize them .09 cents and not penalize EastLink and not penalize Aliant. And then say, okay, Rogers, after you have paid all your .09 cents, we are going to split it evenly. It doesn't make sense to us.
3930 COMMISSIONER DUNCAN: So I take your point. What I am seeing is that some people set it out on the bill, everybody recovers their costs, whether they set it out on the bill or not, that is your point.
3931 MR. DANIELS: That is right.
3932 COMMISSIONER DUNCAN: And so if we take the surplus that shows in your books, how is that fair if it is not showing out in another? That is your...
3933 MR. DANIELS: Exactly, as between competitors. And the other thing I just say on this is that the total dollar figure of the surplus is decreasing every year. So last year, I am going by CRTC numbers here, it was -- again, we don't really like to call it surplus, but that number was the difference between the revenues and the expenses was $10 million.
3934 That is way down from where it was in 2008. And why that is is that the residential phone subscribers are dropping because they are switching to wireless where there is no explicit MRS fee.
3935 So what you have is the revenues are going down.
3936 Now, that doesn't mean that the MRS expenses aren't going down, but they -- they're not related because the people switching to -- on the revenue side to wireless has nothing to do with whether people are using MRS or not. If you switch to wireless, you're still going to use MRS. Like that's -- it has nothing to do one or the other.
3937 So we've got two dynamics, and so I don't even know if the surplus will be there in the near future. And I certainly don't know how you would project it forward from it because there's vast changes.
3938 COMMISSIONER DUNCAN: I think that you've clearly made your point.
3939 So just for interest, does Bell set out -- Bell Canada, this would be -- set out the charges for MRS on their wire line customers? You do.
3940 MS JONES-SHERK: No, it's rolled into -- it's rolled into the home phone cost.
3941 So we don't explicitly call out the 13 cents.
3942 COMMISSIONER DUNCAN: Okay.
3943 MR. DANIELS: But it's in our tariff as a separate --
3944 MS JONES-SHERK: It is.
3945 MR. DANIELS: It's in our tariff as a separate item, so it's not -- I think you know, if the question -- we're not quite sure if you mean on the bill or in terms of how it's actually -- the price is made up.
3946 We -- Bell Aliant does not have -- in your tariff, they will not find an MRS charge as a retail rate. They just have the rate. But whereas if you look in our tariff, you'll see it there.
3947 COMMISSIONER DUNCAN: Okay. And what about wireless?
3948 MS JONES-SHERK: There's no charge on wireless.
3949 COMMISSIONER DUNCAN: No charge for wireless.
3950 MS JONES-SHERK: No.
3951 COMMISSIONER DUNCAN: And that would be the same for all of the companies you're --
3952 MS JONES-SHERK: Bell Mobility is national, so...
3953 COMMISSIONER DUNCAN: Okay.
3954 MS MORIN: I don't believe we have a separate charge for any of the Bell Aliant affiliates.
3955 MR. DANIELS: And Northwest Tel, I don't believe, either because they don't even have one for their wire line as well, so I'm pretty sure they don't have it on their wireless.
3956 COMMISSIONER DUNCAN: Okay. In your submission, you explain that VRS is outside your area of expertise and, therefore, you oppose the MRS approach -- so we'll get into this again -- as carriers and would assume the responsibility of selecting a VRS provider and managing these contracts, you're thinking it's outside your area of expertise.
3957 But -- and I think it's worth reading this. It's lengthy, but I'm going to read it because I think it covers a good point.
"While VRS operators require specialized training to become proficient sign language interpreters, it would appear that the infrastructure associated with VRS would not be unfamiliar to TSPs."
3958 VRS entails call centre operations, human resource management, call routing, termination and other components which you're very familiar with, so could you explain why VRS would be beyond your area of capabilities?
3959 MR. DANIELS: I'm going to give Cindy a chance to help -- to answer this in a second.
3960 TELUS, I think, told you they've actually done a trial, so they've seen it because they thought they might be interested in it and said, "This is just not what we do".
3961 Generally, in talking to the company, there's no one who knows very much about it other than probably the people -- mostly the people on this panel. And I am certainly not ready to run a centre like that.
3962 It really does require a completely different skill how to manage it, how to -- it's not -- even what we've heard about is interpreters who come in, for example, and work partly in the community, do some hours. They have -- they need breaks, longer breaks because it's a much more -- like I think it's just a completely different service and we really have no idea where to start.
3963 COMMISSIONER DUNCAN: Just maybe I could interrupt because it sort of flows into the next question.
3964 Then why wouldn't you just sub-contract that aspect of the service as you would like if you're building fibre networks?
3965 MR. DANIELS: So we certainly would. There's no doubt that we would contract it out.
3966 But then I come back to the question, what are -- why are we trying to find a model where we're contracting out, putting in the middle man and we're going to contract it out and be only driven by one thing, you know, reducing the cost of the service as opposed to having a holistic approach to a social obligation.
3967 When -- like I guess what I'm struggling for -- and I know I'm not the one who's supposed to ask the questions, but I'm struggling to understand the advantage of doing this model in terms of the MRS model and putting the obligation on us and saying just go contract it out.
3968 Like that's where I have a hard time.
3969 I have some guesses as to why there may be some interest in this, but I'm not really quite sure what the advantages are.
3970 The disadvantage, to me, is you're removing the accessibility groups, the -- not participation as much as control or shared control over it and the other issues I raised.
3971 COMMISSIONER DUNCAN: I'm not quite sure that that would necessarily have to be the case that they'd be disassociated with it because there'd have to be standards put in place and monitored. And the development of those standards would definitely have to involve the deaf community.
3972 MR. DANIELS: I totally agree, except to say that I think standards -- establishing standards and having sort of an oversight is one level, and it's quite something altogether different if you look at what the CCTS.
3973 I think you heard from Dennis Béland the other day, who was -- who's still a member of the Board of Directors of the CCTS.
3974 I also was -- I was one of the other -- you know, I'm no longer, but I was. I did a three-year term as a Board of Directors of the CCTS, and I can assure you that the consumer groups and the consumer representatives on that Board of Directors has far more say in how CCTS is run than any standard consultation process you would ever have.
3975 It's completely different if you have Board of Directors at the control that the providers have to answer to as opposed to advisory.
3976 COMMISSIONER DUNCAN: Okay. Thank you. That's good.
3977 We'll consider everything we hear, so that's fine.
3978 MS JONES-SHERK: Sorry. I would like to add a comment to that.
3979 COMMISSIONER DUNCAN: Sure.
3980 MS JONES-SHERK: Personally, I think it's partially, you know, an over-simplification of a solution and also as well as an over-complication of a certain solution.
3981 If you go to one service provider as an example, you still need to decide several -- there has to be several decision-making factors in there, what kind of database for registration and registration do you need to put into place.
3982 You still -- there is no unique solution out there. I think, given the submission from Connectcom, of any one video conferencing to PSTN solution and automatic call distribution to those service providers.
3983 So -- and I don't meant to get into the service details, but I think that's partially why I'm here, is, you know, I do partially have a -- I guess a different level of understanding of the service. But there are very specific elements that have to be considered.
3984 And to have each ILEC or LEC or TSP decide independently and/or separately has long-term consequences to the cost and customer use of the service.
3985 COMMISSIONER DUNCAN: It just leaves me wondering why, if the TSPs can collaborate in this model, why they couldn't -- why would they each do it individually? It would make sense to me that they'd say, look, there's an advantage to us working together on this aspect of it. Why don't we develop that ourselves, jointly negotiate with a service provider.
3986 MS JONES-SHERK: Well, I think you still have to engage the interpreter organization and solve for the interpreter -- the lack of interpreters.
3987 So you know, with the Mission proposal, it lays all those steps out in a very clear manner.
3988 As well, I think it's clear that the advocacy groups need to have some kind of role within the decision making and use of the service as described by the OAD or the Toronto Association of the Deaf. And I do understand this because I work with many of these associations as well as certain complaints or service issues.
3989 As a hearing person, how do I contact and trying to, you know, facilitate or negotiate that is not easy. So creating ease of use is a really important factor.
3990 COMMISSIONER DUNCAN: The --
3991 MR. DANIELS: If I could just put it -- the simplest distinction between the two models is this. The TSPs will participate, will not be the decision makers under our proposal. Under MRS model, the TSPs are the decision makers. And we're trying to come up with a model that basically allows the decision makers to be one who has a much broader holistic view than strictly the bottom line.
3992 Important for the bottom line. Please don't let me undermine that. I'm here from Bell. But not the sole determination.
3993 COMMISSIONER DUNCAN: But wouldn't a CISC model involving all of the others -- all of the stakeholder groups accomplish the same thing?
3994 MR. DANIELS: Possibly.
3995 So I -- there's a difference. I know we talked about the hybrid model and then there's the CISC model, and we really shouldn't have called it a hybrid model because there's the CISC model.
3996 The problem why we're not jumping to CISC is CISC requires 100 percent consensus. If you don't, you have a tiff. You've got this layer. You have a group itself. Everyone has to agree. If you don't agree, there's a dispute.
3997 The dispute goes up. Then it goes to the steering committee. Then it goes up to the CRTC. There's all these layers that we don't think is in the interests of actually getting the service going, having 100 percent agreement.
3998 What I think you need is a Board of Directors who can make hard decisions, who are empowered to make hard decisions. A small, tight group who learn to work together, not -- I don't want to ignore or not have participation in an advisory capacity from all the accessibility groups or all the TSPs, but if you look at the CCTS, if the CCTS had to make every single Board decision at a CISC level thing where everyone agreed, it would not be operational today, or at least it wouldn't look anything as the effective agency it is today.
3999 COMMISSIONER DUNCAN: When the Commission is regulating, of course, and we're dealing with the licensees like yourself, we have -- you know, we know what the rules are. We can control it.
4000 What type of enforcement tools are you proposing for the CRTC with this independent administrator?
4001 MR. DANIELS: Pretty similar to what you have with the CCTS or the others, so back to the diagram.
4002 We -- once the Board -- the interim Board was set up, then all of the constituting documents were set up and so on, it's back to the CRTC for approval. So the CRTC is going to approve it and have the oversight just like it does with -- I keep saying the CCTS because I'm familiar with it.
4003 I should really let Bill talk because Bill's done -- I don't know how many. I've lost count how many he's done of these with -- just recently. How many?
4004 MR. ABBOTT: Three all together.
4005 What comes to mind is the CCTS and, more recently, the broadcasting accessibility fund and the broadcasting participation fund, which -- and -- yeah. So those would be the three formal organizations that we've had experience in building. And in all those cases, the CRTC had touch points, as we're suggesting here, interspersed through the process to exercise control.
4006 COMMISSIONER DUNCAN: So the CRTC would have some option -- some points of control as it evolves.
4007 Once it gets to full operation, what would be the CRTC's control options at that point?
4008 MR. DANIELS: I think the CRTC --
4009 COMMISSIONER DUNCAN: What could they be?
4010 MR. DANIELS: I think it would probably be something similar to the CCRTS in terms of like after it was fully set up, we came back at five years and had a complete review of the CCTS. We had a whole hearing to look at exactly.
4011 There were some tweaks made by the CRTC as a result of that.
4012 And I can't recall, but I think it's another five years before they're back. I'm not sure if there was actually a definite period, but maybe -- whatever you felt comfortable with.
4013 COMMISSIONER DUNCAN: I doubt that there was another definite period.
4014 MR. DANIELS: Sorry?
4015 COMMISSIONER DUNCAN: I don't think there was a follow-up, yeah.
4016 MR. DANIELS: So if it felt the need was that you needed to bring it back, then I think you would do it just like that.
4017 COMMISSIONER DUNCAN: Okay. Thank you.
4018 So I'm just -- so the VRS provider would be selected by the -- in your model, it would be approved by the permanent Board, the VRS providers.
4019 MR. DANIELS: Yes. And certainly the platform would be and, ultimately, the providers would be.
4020 We're -- you know, whether it's one or multiple or whatever, that would be something that the Board would decide in terms of how to structure it and so on. But yes.
4021 COMMISSIONER DUNCAN: And would you see the administrator having any influence over the funding cap?
4022 MR. DANIELS: Yes. I think two things would happen.
4023 Number one, at the get-go, for example, we're suggesting an envelope of $5.3 million, like a concrete dollar figure be assigned to them with the task they have to work within that cap.
4024 They come back to you in two years' time. I think they would be the lead. They would be, you know, the formula saying look, we've got the RFIs. We have a sense of how much the next is going to cost us. Here's the actual dollar figures we need by year.
4025 The CRTC would approve that. They would not be able to set budgets themselves. The CRTC would set the overall for the five years or four years broken down by each year, and they would go and administer and decide how that money is spent based on the guidelines. And they'd be back to you again for the final approval.
4026 So I think you -- the CRTC would actually approve every single dollar that's being spent -- sorry, the overall cap amount. The actual decisions of where it gets spent would be by the Board of Directors as advised by their staff.
4027 COMMISSIONER DUNCAN: Presumably when they presented their estimate or their funds request, they'd substantiate it or show generally how it's arrived at.
4028 MR. DANIELS: Exactly. And that's what we're hoping would happen in the process even in Phase A, is that you're going to get things like the UQUOM proposal that has real dollars so that it's not theoretical. It's we really know what it would cost to get to the next stage.
4029 COMMISSIONER DUNCAN: And would you see sort of a structured reporting requirement for the VRS administrator?
4030 MR. DANIELS: I would. Something -- you know, probably something -- but even more importantly, I would see a structured reporting requirement for the VRS providers to the administrator.
4031 COMMISSIONER DUNCAN: Yes.
4032 MR. DANIELS: That -- I'm less worried about the administrator in terms of what it's going to tell the CRTC, and yes, it should. But I'm more concerned about what the actual providers and people who are using the money tell the administrator. And that's one of the reasons that when we talked about having a common platform, the platform is partly -- it's much more than just Skype or something like that. It's designed to be able to have the systems to be able to make sure that we actually know what the VRS providers are doing out there, reporting in the same way as between the various different providers.
4033 So to me, the more important reporting is between the VRS providers and the administrator, the ones who's paying the money and seeing what they're getting for it.
4034 COMMISSIONER DUNCAN: And do you have some idea on what the type of accountability measures would be that would be put in place, or would it all just be developed by the Board?
4035 MR. DANIELS: Can I clarify, are you talking about vis à vis the administrator to the CRTC or between the VRS providers to the administrator?
4036 COMMISSIONER DUNCAN: I guess just following on your point, it would have to be both.
4037 MR. DANIELS: Right. But --
4038 COMMISSIONER DUNCAN: Yes.
4039 MR. DANIELS: -- would you like -- because I think -- maybe I could ask Cindy to talk about the VRS -- the providers to the administrator. As for the administrator to the Board, we haven't really thought about that.
4040 COMMISSIONER DUNCAN: Okay.
4041 MR. DANIELS: But maybe Cindy, do you want to --
4042 MS JONES-SHERK: Well, I would see the reporting from the service providers would be fairly, I guess, typical of most call centres, so they would be reporting on average call handling time, speed to answer, quality of service parameters, complaints. So similar to any call centre process.
4043 I would assume also there'd have to be certain call flows created and followed, so that kind of adherence, as well as probably, obviously, employee relations, code of conduct, things like that.
4044 COMMISSIONER DUNCAN: Okay. I'm just wondering, on the -- you're clear on your model and you've commented on the other two models. But I'm just wondering if it wouldn't be worth just going through the other two that we have and you can tell me specifically what you -- I know right off the bat what you don't agree with.
4045 But hybrid model with obligations still placed on the LECs by tariffs and subsidization through a centralized fund. And the TSPs would be required to contribute to the national contribution fund to pay for the VRS. However, some of all of the LECs would be responsible for the provision of the service and would be required to file a tariff with the terms and conditions.
4046 The fund administrator would provide each LEC with an amount set by the Commission to subsidize the cost of providing the service.
4047 MR. DANIELS: So from the collection side, obviously no issue. We totally support -- that's the part of the hybrid, the part that we like.
4048 The other one, no surprise, we're opposed to. It -- basically, it's the whole issue of you're giving us the control as opposed to giving it to the body that can really look at it from the social, interpreter -- the whole aspect of it. I'm not sure I can offer more.
4049 COMMISSIONER DUNCAN: And what I'm understanding is that it's not that you don't want control; it's that you don't feel it's the best place to put control.
4050 MR. DANIELS: That's correct.
4051 COMMISSIONER DUNCAN: So I'll just go through the next model so we have it on the record.
4052 So in this model, this was what we were -- the fourth model -- is funded through a centralized fund to which all the TSPs or some sub-set contribute and a third party VRS provider would be selected through a CISC process by a group representing the industry, organizations representing the deaf and interpreter organizations.
4053 The CRTC would then approve or reject the recommendation. The LECs would remain responsible for providing the service and would be compensated from the fund.
4054 So you've already explained to me what the drawbacks are of the CISC process.
4055 MR. DANIELS: The very last part was, I always thought this was CISC, then CISC, the way it was articulated up until now, CISC would hire -- would do the RFP and then hire the provider. But there is a last little part that you said about the LEC which I thought --
4056 COMMISSIONER DUNCAN: It said the LECs would remain responsible for providing the service and would be compensated from the fund.
4057 MR. DANIELS: I just --
4058 COMMISSIONER DUNCAN: Same problem.
4059 MR. DANIELS: Why are -- why would we be paid to do something that someone else is doing? You're just putting a middle man in there.
4060 COMMISSIONER DUNCAN: Okay. And TELUS' proposal yesterday, did you have any comments on it?
4061 I think you may have mentioned something on that earlier, but...
4062 MR. DANIELS: So TELUS is -- we think we have a general similar approach, but ours is -- where we diverge from TELUS is TELUS is suggesting let's go to CISC and then let's just put this out to RFP and get one provider.
4063 And I still think that runs the whole risk, one, it could get bogged down in CISC. Two, more importantly, from our perspective, of -- that even if it doesn't get bogged down in CISC, that if you're just going to choose one provider, we're going to lock ourselves in to someone who we're stuck with for all time in the future.
4064 We really believe in a model that says, one, interpreters, go slow, build up the base. You've heard me say that.
4065 Ignoring that issue and just talk about we really think it's important to separate the platform from the actual providers themselves.
4066 And part of our vision on that is, at the end of -- let's say we put out and hire a platform. At the end of five years, we want to be able to make sure that we own that platform or have a licence so that we can switch, we can take different approaches, we can go into different directions. We're not locked into any particular technology.
4067 And as part of that as well, there could be technological advances.
4068 I noticed that you had -- you commissioned the -- let me get the name right here -- the Connectus report, and -- which was very interesting in terms of talking about that there's all sorts of projects, nine projects around the world working on different avatar solutions and so on and so forth.
4069 And I've also listened to the critique that if the technology is not there yet today that you can't capture the facial expression -- I've been watching the interpreters this week and understanding what that means.
4070 But I don't know what the future has, and we want to make sure that we have an approach to this that's flexible and allows us to go and to adapt and change to a cheaper technology as long as it meets the service needs, which may not be here now, but maybe in five years.
4071 So I don't know what that model is, but I do believe that separating the platform from the provider will really help to ensure that we have the flexibility to change directions without being locked in and having to basically like the -- you know, the U.S. is sort of stuck in there -- I don't think the FCC loves their model, and yet -- I'm not an expert on it, but I have the sense that they don't love their model. And yet they're having a hard time moving because of -- that's what everyone -- you don't want service affecting.
4072 So we want to build this right from the ground. And my concern with the TELUS approach is it says go to one provider, platform everything together and then we're sort of stuck with that.
4073 COMMISSIONER DUNCAN: So just to help me understand further, if there are two providers or three providers, as a user in my home, what difference would I now -- like would I be able to say no, I want switching like from phone company to phone company or cable to television.
4074 How would it affect me in my home?
4075 MR. ABBOTT: Under the -- if we look at an example where there is -- where there are multiple providers -- I'm thinking of the U.S. -- there are -- there can be -- it can, in fact, be very clear distinctions.
4076 My understanding is that you identify a default provider. That's the provider you're most comfortable with. But you may use others.
4077 For example, maybe that one's great for just casual calls because they're fast to answer. There's almost no waiting time. But when you want to talk to your doctor or to your lawyer, you want to go to a different company that has specialized interpreters. It's kind of a boutique and it's known for this sort of thing.
4078 Now, maybe you wait 10, 15 minutes to get through, but once you get there, you get someone who really understands.
4079 So there could be -- from the service perspective of what really counts in the service, which is sign language interpretation -- because you can get distracted by the technology. But that's just wheels.
4080 What really counts is the sign language interpretation, and there can be clear distinctions in capabilities and speed to answer and all the rest.
4081 So at that level, I think someone would -- could very well see a difference, depending on what their needs are.
4082 If you're saying at the technical level, you know, if it's this protocol then that protocol, probably you wouldn't notice a whole lot.
4083 COMMISSIONER DUNCAN: Okay. Thank you. That helps. Thank you.
4084 I'm just wondering about undue hardship and how you would measure undue hardship.
4085 MR. DANIELS: In the telecom context, we tend to talk unjust discrimination under the Act which is, I think, the power and the test. And we believe it's proportionality test that looks at in terms of, you know -- so if that's what you mean and if you're referring to -- when you say measure it, do we mean that all subscribers -- how much all telecom subscribers would pay for the service or -- maybe you could tell me --
4086 COMMISSIONER DUNCAN: Well, what we're thinking is that we're required to provide the service up to the point of undue hardship. So whatever that amount would be, we'd be required to do it until you can say that no, if it's $200 million, that's undue hardship for the companies, for the -- for Canadians. So the point of undue hardship.
4087 MR. DANIELS: I think we're probably talking about the same thing, which is a proportionality test.
4088 My discomfort with that term is that that's actually a legal test that's under the Human Rights Act. That's not --
4089 COMMISSIONER DUNCAN: It is.
4090 MR. DANIELS: -- the test under the Telecom Act. And --
4091 COMMISSIONER DUNCAN: And so our interpretation is that that does apply in this instance.
4092 MR. DANIELS: Okay. Maybe I can -- because I think my understanding of the submission is that the proper test would be the language that you've used, which is the polycentric approach, but maybe I could ask Bill to talk more about that.
4093 MR. ABBOTT: That's correct. In the -- I mean, the Commission has clearly dealt with other social policy issues and had to struggle with, you know, what's the test. How far can we ask people to go?
4094 And in its prior decisions, including 2004-47 and 2009-430, it has quite explicitly said, you know, there's this test, the undue hardship test, under the Canadian Human Rights Code. But we wouldn't be doing our job if we just focused on that to the exclusion of other things because you have a much broader ambit than the Canadian Human Rights Commission.
4095 You have to balance a number of other issues. And consequently, the Commission has adopted a polycentric analysis balancing a number of different issues.
4096 And the threshold at which it's balanced under 27(2) is the unjust discrimination-undue preference. And you know, I think we covered this to a certain extent in a separate proceeding that they're very distinct tests, that the 27(2) test under the Telecom Act is a different test, a different threshold and you consider a number of different -- a number of different factors.
4097 Under the Canadian Human Rights Act, it's quite clear that there's one test, the undue hardship test, and that's the only thing you look at.
4098 MR. DANIELS: But having said all of that, at the end of the day, we're still looking at it here and saying does the Commission have the jurisdiction. Absolutely. Should it exercise it? Absolutely.
4099 Here's the way to go about doing it in terms of -- and what we like about the legal analysis and everything is it says what you try to do is let's get the service into the hands of the people in a way that works for everybody using a method that has the cheapest way of doing the service to meet their needs.
4100 So if that's the goal, that's -- like we're 100 percent signed up to that.
4101 COMMISSIONER DUNCAN: Okay. So I appreciate that. So that is the goal.
4102 So you haven't turned your minds to what would be the limit. At this point, you're going to do it the most efficient way possible and you don't see that being an issue.
4103 MR. DANIELS: Part of where we've been drawn to is about the undue hardship, if you will -- and I use that term colloquially, not legalistically -- but on -- the impact on the communities generally if we just went with one way as opposed to what we believe is the better way to go about doing this.
4104 But having said all of that, yes, I think -- I agree with what you said and then, you know, it's a question of just trying to find the cheapest way to do it.
4105 COMMISSIONER DUNCAN: Okay.
4106 MR. DANIELS: Within reason.
4107 COMMISSIONER DUNCAN: I think what I'd like to do is ask the Chairman if we could take a 10-minute break and come back after 10 minutes.
4108 THE CHAIRPERSON: Yes. We will take a 10-minute break.
--- Upon recessing at 1242
--- Upon resuming at 1251
4109 THE SECRETARY: Order, please. I would just like to announce that we will take lunch right now, and we will be back at 1:30 with Bell.
4110 Thank you.
--- Upon recessing at 1252
--- Upon resuming at 1342
4111 THE CHAIRPERSON: Order, please.
4112 With the Secretary's permission, I think we'll resume.
4113 THE SECRETARY: I give you permission. You may continue.
4114 COMISSIONER DUNCAN: Okay. Thank you. That certainly gave us a chance to pare down our questions based on all the full description that you were giving us in advance. So I don't have too many more questions.
4115 But first of all with respect to the 5.3 million that you suggested for Phase A in your document, we were just curious about the composition of it and wondered if it is made up in accordance with the Mission Consulting report breakdown.
4116 MR. DANIELS: The short answer is, yes, it's straight from Mission. Maybe -- I don't -- yeah, we can find -- we wouldn't make up the figure. No, I mean we're very happy having no idea as to -- they did the work and made the estimate, so --
4117 COMISSIONER DUNCAN: Okay.
4118 MR. DANIELS: -- we're relying on that.
4119 COMISSIONER DUNCAN: All right. I was curious just on the training. As I understood what you were saying was that the actual training of interpreters or the launch of the interpreter programs that you'd see putting in place wouldn't end up being in place until the end of 2015, but it would seem that the need for interpreters and the reason to start the training would be well in advance of that, and wouldn't you see the administrator getting those programs in place first?
4120 MR. DANIELS: No in terms of the administrator -- we don't the programs can actually go and do their thing until the platform has been chosen because the programs themselves have to conform to the platform. Did I get that -- that right?
4121 COMISSIONER DUNCAN: So I'm talking about interpreter training.
4122 MR. DANIELS: So maybe I -- again, we're stuck with Mission, and Mission may be better to describe this, I know they're here tomorrow, but maybe I'll let Cindy just address this.
4123 MSJONES-SHERK: I think part of -- part of the intention - sorry, Jonathan - is that's where the RFI would come into play because then it would allow, as an example SIVET and UQAM have provided their proposal, but people to understand what resources they would require in order to ramp up their training program. As we understand right now, the univers-- or universities - excuse me - and colleges who provide training today, and this is in the Mission report also, have no capacity to increase the number of interpreters that they graduate today. So ASL is about 51, I understand, per year, the other is 6 for LSQ. So that's clearly a very insignificant number. So -- so that would also have to be organized. So that's why there's a little bit of a gap in between there.
4124 COMISSIONER DUNCAN: Okay. All right.
4125 And with respect to the second phase that you call Phase B, the 2016 - 2019, I understood you to say that the board would come back to us or the CEO would come back to the Commission for approval of the next allotment of funds, if you like, but I'm just wondering, if you have a range in mind there, what that would look like, the requirements and how that relates to your schedule on page 8, Appendix B.
4126 MR. DANIELS: So, Mission has -- gave -- gave some ideas as to what the -- what the -- the kind of money that we would be talking about and that's the ramp up. Again, they may be best to explain that. I can --
4127 COMISSIONER DUNCAN: So you're referring to the Mission report? That's how you see it?
4128 MR. DANIELS: So this is all Mission.
4129 COMISSIONER DUNCAN: Okay.
4130 MR. DANIELS: This is really -- the difference that -- between us and Mission is, one, we're putting in what role the CRTC plays. I don't think Mission had a very explicit about that. And two, we are suggesting we change the name so that you really understood what happens in the pre-- the pre-phrase, but they had just sort of -- they referred to and talked about the money, but we're putting timelines down to it, very specific. They said up to 18 months and that's -- we're, again, consistent on the basis of your decision coming out in the first quarter --
4131 COMISSIONER DUNCAN: Okay.
4132 MR. DANIELS: -- of next year, that's 18 months --
4133 COMISSIONER DUNCAN: Okay.
4134 MR. DANIELS: -- for an implementation. So it -- they'd be the best to -- but it's in there. They have a --
4135 COMISSIONER DUNCAN: All right.
4136 MR. DANIELS: -- they have a -- an estimate of what it would be like.
4137 COMISSIONER DUNCAN: The -- sort of related. The FCC, the dock at 1382, indicated that the VRS weighted average cost for all supervisor -- service providers is $3.40 a minute. Is there any reason to believe that this cost in Canada should -- is not the same as in the United States, should be higher or lower? Any explanation for why it would be different?
4138 MR. ABBOTT: I think there -- there are a lot of difficulties with -- well, actually, you know, the first simple answer is we don't know and that's why you need these phases, to find out, and I -- because I can't give a short answer. Some of the other variables in -- in there is that that's a number based on a mature market, mature service providers. It's been around for 12 years. They don't have ASL and LSQ, which is probably a factor that will affect cost. It's -- we're really sort of apples and oranges.
4139 COMISSIONER DUNCAN: Okay.
4140 MR. ABBOTT: So, it is likely going to be higher, potentially lower, but it seems -- it's -- we just don't know --
4141 COMISSIONER DUNCAN: Okay.
4142 MR. ABBOTT: -- and that's why we need the -- the Mission approach to -- to build the information base to make intelligent decisions in a timely way.
4143 MR. DANIELS: If I could just add. You know, the way I sort of look at the U.S. example, the U.S. example is kind of a -- a traditional regulatory approach. Give us a cost that we're going to try to figure out. Now there's a whole battle going on about the costs, that they don't like the rates and so on. Wherein the FCC really wants, I think - I think, and, again, I'm not -- and keep me honest here, Bill, because I haven't really looked at this closely enough, but my understanding is ultimately to move -- they'd like to figure out a way to move to a more competitive model. I don't mean -- because it's very competitive in the States vis-à-vis users. They get to choose whatever provider they want and there's lots of service, excellent service provided in the States as a result of that. But in terms of the price for the actual service, it's dictated by the FCC and it's based on a cost study or arguments about what -- the costs and how to properly characterize it. What we're suggesting here in Canada, and, frankly, every other country, I think, in the world has pretty much gone to, let's put it out to RFP. Who knows if the lowest price is 3.49. It could be a lot less, and maybe we do it on a per seat as opposed to a per minute, whatever. There's different variations. Let's let people compete and come. There's no incentive for any of the carriers in the U.S. right now, I don't think, to actually come and say my price is lower than the other guy because they don't win business on the basis of having the lowest price. That's not how they compete in the -- in the U.S. and I think that's fundamental to the U.S. model, which we are obviously very loudly opposed to, but that's why we're cautious about looking at financial estimates because we don't know what the actual costs would be if we had true RFPs and competition for win -- win the business.
4144 COMISSIONER DUNCAN: Just following up on that then. When the RFP process is put in place, do you think it should specify that they should quote per minute, per user, flat fee, per operator, or should it just be left open so you get as much innovation as possible?
4145 MR. DANIELS: This is where I think there's a benefit of the difference between the Phase B stage and the Phase C stage, so ... As -- vis-à-vis Phase C at the end, I have no idea. I really don't. Is it best per minute, is it best per seat, I don't know. And I don't think we generally know in Canada.
4146 However, in Phase B, I think the interpretive agencies and the collection will come up with a whole bunch of different proposals. They'll be experimental. Some of them may be per seat, other may be per minute, and the administrator, I think, will look at that and learn from that to decide how they want to design Phase C. And when I say "the administrator", they're going to have a staff, a professional staff who learns all of this but then is -- you know, has it get it approved by their board, made up of TSPs who are worried about the dollars and accessibility groups who are worried about the service.
4147 COMISSIONER DUNCAN: Okay. Perfect. Thank you.
4148 The -- just looking at your -- again at your Appendix B, do you have a feel for where the minutes might end up? Between 37 and 60 or some other average minutes?
4149 MR. DANIELS: What we -- we have no feel whatsoever and I appreciate that you -- that you're -- that you're out there asking for it. The Mission and the Sorenson numbers are clearly different at 60 and 37, but the Mission numbers, as I understand it, is actually -- it's based on the U.S. average and then they took it down because there is a couple of they called it anomalies in the -- in the U.S. system. And so they specifically said that there's an overstimulation of use in the U.S. because of the nature there are some anomalies. And so they consciously took it down from -- I'm guessing the U.S. average is 53 and I just did that by working backwards [indiscernible] and calculated their 37. So I think there's sort of general agreement that in the U.S. it's probably in the 50 to 60 range, like Sorenson says right now, not in the Telus range, but as to where that number actually would be and how much to go down, we have absolutely no idea. We've never experienced it.
4150 COMISSIONER DUNCAN: Okay.
4151 MR. DANIELS: I'm so sorry.
4152 COMISSIONER DUNCAN: The -- in the -- and again, you're probably -- you're not really going to be -- maybe have a view. In the 5.3 million, are there funds allowed in there for the disability groups to participate? Because there will be a cost for them to participate.
4153 MR. DANIELS: Absolu-- absolutely.
4154 COMISSIONER DUNCAN: If it's provided for.
4155 MR. DANIELS: The -- one of the reasons I think I said we estimated $1 million up front, in our experience in setting up the -- the other --
4156 COMISSIONER DUNCAN: Accessibility clients.
4157 MR. DANIELS: -- like CCPS and others --
4158 COMISSIONER DUNCAN: Yeah. Yeah.
4159 MR. DANIELS: -- we've spent a lot less than that and we bumped that up ourselves. This is not Mission. This is ourselves and looking at what would you need in the first year. It was the assumption that we're going to have to spend a lot more money in interpreters, in bringing people together so they -- you know, one way or another it's going to be a -- a -- so yes.
4160 COMISSIONER DUNCAN: But, Mr. Daniels, you said the 5.3 was the Mission number but then you bumped it up or?
4161 MR. DANIELS: No. As I said, it -- 5.3 is the Mission number.
4162 COMISSIONER DUNCAN: Yeah.
4163 MR. DANIELS: I don't have the breakdown of how Mission came up with their 5.3.
4164 COMISSIONER DUNCAN: Right.
4165 MR. DANIELS: Or I didn't really look into how they came up with their 5.3, as much as I saw that they listed all the things that they were going to do. When we ourselves said, okay, we're coming to the Commission, we're presenting today, we need to tell you how much to allocate in 2014 as opposed to 2015, based on looking at what we think needs to be done in 2014, which is the thing we have the most experience in, we decided, you know, a certain figure and then we -- we bumped it up as a percentage of -- and said, no, you probably need more, let's take it up to a million dollars of the 5.3.
4166 COMISSIONER DUNCAN: Okay. All right. Thank you.
4167 And I'll just ... I just want to make sure that I haven't ...
4168 The mobile broadband that you've heard questions asked through the week, about whether mobile broadband can deliver VRS at a reliable service level, so we'd be interested in your comments on that.
4169 MR. ABBOTT: We agree with the position that cable put forward with respect to it. It's -- of all the issues that we -- the Commission has to worry about, that's probably not a big one. There are a lot of packages available out in the -- in the marketplace that appear to accommodate it. And as far as the technology, it exists in other countries and appears to work. We don't have firsthand experience with it, but it seems --
4170 COMISSIONER DUNCAN: So you don't think that there'd be periods in the day that congestion would affect the mobile delivery such that you wouldn't be able to see the pictures as clearly because the expressions are so important?
4171 MR. ABBOTT: It's possible. That's -- I mean, it's a very subjective situation. It's going to be made up of the connectivity, the device you have, and the application you have. When I was in the middle of Algonquin Park, I had no cell service. Fantastic actually. But it'll happen. It depends on whether you're in the parking garage or you're in the -- in the clear. I -- we do know that it is possible to have the bandwidth wirelessly to support it. We can't really say much more than that.
4172 COMISSIONER DUNCAN: Okay. The -- with respect to 911, and these three questions you may prefer to take as an undertaking, but because we are looking for some meat here, to what extent does the existing 911 network support direct access to 911 operators by VRS users? What extent would it?
4173 MS MORIN: My understanding of how the 911 system works today, there's a difference when you speak of direct access, the VRS operator to the 911 operator versus dialing 9-1-1 through the VRS operator and the PSAP having direct access to video. The latter is not the case and that's the same in -- PSAPs just don't have the capability today to receive video directly, but VRS is similar to IPRS. And so, today there are -- you kind of go through a call centre in order to acquire the information, the location, and contact details of the customer because that information in the MRS world flows through directly, whereas it doesn't in this case. So it's not a -- it's not a situation that's unique to VRS, as we mentioned in our opening statement. So it's something that we're looking at in the IPRS next generation context. So VRS definitely should be at the table and part of the considerations and, you know, the PSAPs are not here this week, but they definitely need to be at the table.
4174 COMISSIONER DUNCAN: So can the 911 access be provided through those same operators? Access for VRS service be provided through your existing operators, is -- or is that going to involve more technical adjustments?
4175 MS MORIN: Well, today for MRS --
4176 COMISSIONER DUNCAN: Yes.
4177 MS MORIN: -- you do have direct access.
4178 COMISSIONER DUNCAN: Yes.
4179 MS MORIN: For IPRS, telecom service providers do inform their customers that they should not use it for 911 because of location and that information doesn't flow through. For those who do still use it, it passes through a separate call centre, where they try to obtain the information that they can based on the user profile and if they can still speak to the user.
4180 COMISSIONER DUNCAN: Yes.
4181 MS MORIN: You know, we would envisage something similar for VRS, but one of the things as well, given emergency calls are so important, and I think we did hear that from some of the stakeholders who appeared before us this week, that, you know, at least they have to have in place protocols to deal with if there really is an emergency and what are they going to do in that -- in that circumstance. But to have the -- the automated, everything flows through, that's just not available today.
4182 COMISSIONER DUNCAN: So --
4183 MR. DANIELS: Can I just clarify. When you say the word "direct access", and I appreciate you're getting -- the staff being very specific and I'm sure there's somebody looking at it, direct access meaning that the person -- the deaf person who is using it even for a TTY device today generally would not go directly to -- not to the PSAP itself. There -- the PSAP -- in order for that to work, the PSAP would need a TTY device there. Now, there are, I believe, some -- like, a couple that do do it, but almost all of them today go through our service. So if direct access meant VRS going directly to the PSAP so that they're talking the first respo-- like, the PSAP itself, the police service answering service, I don't think you'll ever come to the day where there's so many PSAPs across the country and that would require each of them to have an interpreter sitting there for that. I think realistically it will always have to go through -- when the day comes to do 911, it would have to go through the -- the VRS provider providing the service. So, meaning where is the interpreter going to sit? It's not -- the interpreter --
4184 COMISSIONER DUNCAN: Oh, no. Okay.
4185 MR. ABBOTT: -- is not going to sit at the PSAP and that -- I just wanted to make sure we were clear because there is a couple examples of direct access today if "direct" means right to the PSAP, skipping the interp-- skipping the operator service.
4186 COMISSIONER DUNCAN: So the question is how do you propose the 911 access be provided for VRS users? And your answer was, I think, it has to be developed?
4187 MS MORIN: Exactly.
4188 COMISSIONER DUNCAN: Is that the answer?
4189 MS MORIN: Exactly.
4190 COMISSIONER DUNCAN: Okay. All right. Thank you. Yeah.
4191 And -- so then the next question was could the approach to 911 service for nomadic VoIP service be used to provide access to 911 service for VRS?
4192 MS MORIN: I think that's what I was trying to explain before. Because VRS is IP based, similar to IPRS, that there -- there could be a potential that it would go through a separate call centre and that would be something that the VRS provider might be required to provide through an RFP. But again, I think the -- the administrative board needs to sit down with their stakeholders and get the PSAPs there and everyone there in order to figure out is that an appropriate protocol in the context of VRS --
4193 MR. DANIELS: And --
4194 MS MORIN: -- for that interim period.
4195 MR. DANIELS: And I think you used the term nomadic -- nomadic VoIP there as well. And so, I think it's the same issue. Like, if Vonage today, the -- the whole issue is you have to go through a separate call centre who says where are you located and then they connect you to the actual PSAP. I think once the service is set up, the VRS would do that, just much like it's the same issue of IPRS, VRS, and the nomadic VoIP. So I think if the question is do we have to look at that kind of solution, then yes. Some -- there's issues that need to resolved, but yes.
4196 COMISSIONER DUNCAN: I think that's the -- that's the bottom line, it has to be resolved. Okay. Thanks.
4197 And so I wanted to ask you some questions on the -- how the fund would be calculated, the contribution would be calculated. And so you're proposing the Canadian Telecommunications Service Revenue before any deductions should be used for funding, so that would include the internet revenue and so that broadens the base?
4198 MR. DANIELS: Correct.
4199 COMISSIONER DUNCAN: Okay. So -- so other parties have proposed the only change from the contribution regime is retail internet revenue should be subjected -- should be subject to VRS funding. Can you tell us your views on only including retail internet revenues in the VRS funding --
4200 MR. DANIELS: Actually --
4201 COMISSIONER DUNCAN: -- that being the only adjustment?
4202 MR. DANIELS: I think when I said correct about CTSR, I actually think that the question that was being asked is absolutely correct, that we would want it to be equivalent of how contribution -- forgive me, I'll get technical for a minute, but they'll understand, the CER allows certain deductions --
4203 COMISSIONER DUNCAN: Right.
4204 MR. DANIELS: -- for intercarrier payments.
4205 COMISSIONER DUNCAN: That was the point, yeah.
4206 MR. DANIELS: For -- if you're going to include internet, you also would not include -- you would allow for the deductions for -- for certain intercarrier payments. So we see it doing the same way that contribution is done today, just including internet and allowing the same deductions that's done.
4207 COMISSIONER DUNCAN: Okay.
4208 MR. DANIELS: It's not quite exactly the language that they said there, where you only look at the retail. We're suggesting doing it like contribution, but I think they'll -- it gets to the same place and it's the way contribution is done today for the voice service. We're saying do the same thing for internet. You take the total revenues and then you deduct any intercarrier payments.
4209 COMISSIONER DUNCAN: Okay. So I think one of the initial concerns we had was that it seemed that you were saying not even to deduct the -- the deductions that are currently in place but those in addition to these intercompany payor fees related to carrier fees related to internet?
4210 MR. DANIELS: Quite honestly, we hadn't thought about it until the question on Monday. And as soon as we heard it, we said --
4211 COMISSIONER DUNCAN: Okay.
4212 MR. DANIELS: -- oh, we obviously articulated that wrong. So --
4213 COMISSIONER DUNCAN: Oh, okay.
4214 MR. DANIELS: -- staff caught us or -- or the Commission --
4215 COMISSIONER DUNCAN: Right.
4216 MR. DANIELS: -- whoever.
4217 COMISSIONER DUNCAN: Okay. All right. And I think that concludes my questions, thank you very much, and I'm sure the others have questions for you.
4218 THE CHAIRPERSON: Thank you. I just have a quick few, I think.
4219 The grants for interpreter training programs and the training agencies, how would you set that up? I mean, do you just go to them, ask them what they need? Do you say we have money, who wants some, and have them come to find the need? Is -- would those -- what I'm trying to get at, would those be direct grants or would the administrator be getting into the business of training itself?
4220 MR. DANIELS: I don't think the administrator would be in the business of training itself, so it would be -- it would be direct grants. But in terms of -- I think we saw proposals like the Yukon proposal coming foward and saying this is what we can do. We expect there would be different types of proposals and they would evolve over -- like, the money isn't to be given out, I don't think, all in the first year. In -- when you get to Phase B, there's a ramp up over four years as -- as -- you know, so as -- as we see what works and we -- we find other ones. So more than that, I don't know if anyone else on the panel -- or we should ... We're a little careful to be -- you know, Mission knows better.
4221 THE CHAIRPERSON: You know, it's okay to say "I don't know" and flesh it out. But if there's -- if there's bones on it, I just want to know what the bones are, so ...
4222 MR. DANIELS: Right. Again, I think the bones are best to ask for -- or to put the flesh on the bones would be to ask Mission, but what I am -- to be clear, the administrator would not be doing it itself. The administrator would be --
4223 THE CHAIRPERSON: Okay.
4224 MR. DANIELS: -- giving out funds. That's good. That's -- that's ...
4225 And there's a question from legal regarding whether your proposal would -- could effectively make the administrator a carrier as defined in the Telecom Act, i.e. a person who owns or operates a transmission facility used by that person or another person to provide telecommunications services to the public for compensation.
4226 I'm going to guess, because you said it was for free, that it's not for compensation, but ...
4227 MR. DANIELS: I also don't see the administrator as being the service provider. I see them contracting out --
4228 THE CHAIRPERSON: Yes.
4229 MR. DANIELS: -- the actual provision of the service, so I would --
4230 THE CHAIRPERSON: Thank you.
4231 MR. DANIELS: -- think the answer would be no.
4232 THE CHAIRPERSON: Oh, in Phase A in your chart, when you talked about the groups being involved, accessibility groups I think was the term you used, just for clarity on the record, by "accessibility groups" you mean deaf and hard of hearing?
4233 MR. DANIELS: Yes.
4234 THE CHAIRPERSON: And -- yes. Thank you.
4235 Where does the initial seed money come from? The contribution fund?
4236 MR. DANIELS: That's -- that's the specific request of the $5.3 million --
4237 THE CHAIRPERSON: Okay.
4238 MR. DANIELS: -- 1 million in 2014.
4239 THE CHAIRPERSON: Thanks.
4240 MR. DANIELS: That's the seed money.
4241 THE CHAIRPERSON: The one thing here is concern is where in this process or how can you assure us within this process that there are sound fiscal checks and balances? Because basically what you're saying is what everybody knows, there's a lot of things that are unknown. And one of the things we don't know is how much it's going to cost, and one of the things we have to grapple with is how do we say okay to something when we don't know how much it costs, and how do we make sure that it doesn't become a runaway train. So maybe you can give us some comfort in showing us at what points in this the system itself will apply -- will create a quality system at an affordable price? Because for the providers, if -- they can move the cost along to their subscribers, but what's -- what's protecting the subscribers' interests that it doesn't suddenly become a 200 million dollar plan?
4242 MR. DANIELS: Okay. Well, first of all, I -- we as TSPs, although we pass on costs to our subscribers in effect, I think we're very much directed or incented to make sure that this costs as little as possible. We don't like to have other fees charged to our customers through us as the instrument for doing it. I can think of numerous examples of times when we tried to reduce the actual cost. For example, you could say the CCTS, you know. I sat -- I think I mentioned to you I sat on the board of directors of the CCTS, and the TSPs were very, very concerned about the total cost of the CCTS. Now, you could say ultimately it's all collected, if there's fees it's just passed through and so on, but I can tell you the TSP directors were totally focused, so -- on that issue. It was our ... And there are safeguards built into the CCTS, into the constitating -- constituting documents to achieve that.
4243 So in terms of the concern, first and foremost I can assure you the TSPs who we are including as part of the process, that will be our focus as part of this. We want to bring out the service and do it right, but we are going to be totally focused on making sure that we do it in the cheapest --
4244 THE CHAIRPERSON: Right. But you might not be the majority on the board, right?
4245 MR. DANIELS: Well, but their suggestions, including in Mission, that there be some control over -- over costs, that there be -- like there is at the CCTS. We are not the majority on the board. We should not be the majority on the board.
4246 THE CHAIRPERSON: Yes.
4247 MR. DANIELS: But on costs there are certain vetoes that are established in the CCTS structure that belongs to the TSPs collectively.
4248 THE CHAIRPERSON: Okay.
4249 MR. DANIELS: But the second thing is we're also saying that every year's annual budget, it may not be done on -- every year that we come to you -- we come to you, but that the administrator should come to the CRTC and get approved for the total amount of money consistent with our notion that there be a total cap. So, we don't ever see the TS-- the administrator, even with the TSPs agreeing, being able to levy an extra charge without CRTC approval. And that's why we're saying the first two years, we're here today suggesting $5.3 million, back in two years to suggest what the next four years should be broken down by year for CRTC to approve and thereafter.
4250 THE CHAIRPERSON: All right. Okay.
4251 Would a cap be useful initially to set a framework or would it be -- sometimes everything goes up to a cap, right? We say that in the first year it can be -- or the first three years it can be no more than X the first year, Y the second year, Zed the third year.
4252 MR. DANIELS: We, you know, absolutely need a cap every year, but we are not in a position to set the cap now is what we're saying in terms of -- because we don't know what the costs for the next stages are, but we think you need a cap for every single year, and that -- and that's why we're saying that's --
4253 THE CHAIRPERSON: At what stage would that cap be established?
4254 MR. DANIELS: Right now for the next two years we're suggesting you set the cap at 1 million and then 4.3 million. That's a cap.
4255 Then they're back to you and back to Appendix A and in the second CRTC proceeding too, to set the cap for 2016 to '19, the four years. Set the cap in that one proceeding and then back to you again to set the cap thereafter.
4256 THE CHAIRPERSON: Okay. Is there anything that could happen to make it happen faster or do you just think that logistically this is as quick as we could do it, the plan you have laid out?
4257 MR. DANIELS: It depends what stage you're talking about. If it so happens that for some reason the board got set up really quickly in Phase A and the RFPs came in and ran, I suppose it could happen quicker.
4258 I'm sort of sceptical. I really think it would take 18 months to pull off. I think it's a tall order for what's listed there in 18 months but doable.
4259 As for Phase B, depending on what the response is, if the interpreters are there and the capacity can be grown quicker and people come back, maybe Phase B can cut shorter. It could be that it could be shorter.
4260 I think we -- to be quite honest, I have no idea and we're just relying on Mission in this are.
4261 THE CHAIRPERSON: Yeah.
4262 MR. DANIELS: It's possible, but if there's real success in terms of the proposals that the administrator says, you know, we don't need a four year Phase B, if we've got the interpreters and we've got the -- you know, we think the capacity is going to be there in two years, I would think the administrator would then be back to you to say, let's go to Phase C now.
4263 THE CHAIRPERSON: Okay. I think just one more.
4264 When you were putting your board together and working with the groups that are going to work with the TSP, do you have any idea what criteria would be used or where would the criteria for selecting the participants on the board for the structure of the board, where would those be developed?
4265 So if I was part of the deaf community and I wanted to be a participant on that board, how would I know whether I met the criteria or would you work with them to help develop that?
4266 MR. DANIELS: I think maybe I can hand over to Bill who has had a little bit of experience in the BF and then I can talk about the CCTS on that.
4267 MR. ABBOTT: And each -- you know, each situation presents its own challenges. But we met this challenge exactly in getting the various elements together for the Broadcasting Accessibility Fund.
4268 In that case the accessibility community and organizations were split into four different categories being sight, hearing, mobility and cognitive. That had its own challenges because there are some cross-disability organizations. There are also sort of two pan-disability directors.
4269 Ultimately, it was done by way of -- we ran a -- the interim board, I should say, ran an impartial election. Organizations could -- in order to be able to vote they had to establish that either they had been incorporated for at least a year or that they had a membership of 20 individuals on an unincorporated basis so that we have some sense of stability and representative capacity.
4270 Elections were run and it actually worked quite well. The feedback from the community was largely positive.
4271 THE CHAIRPERSON: Okay, thank you.
4272 In terms of MRS, and I won't repeat the discussion about -- the debate about surplus -- but in the Sorenson submission they noted that usage of TTY dropped 87 percent after VRS was introduced and IP relay dropped 51 percent. There has already been discussion in this hearing about usage being not what was anticipated.
4273 Do you think it would be appropriate to be reviewing the MRS structure in concert with the development of VRS to make sure that it was appropriate, reasonable, et cetera?
4274 MR. DANIEL: I think it would be appropriate to do that, but it's premature meaning besides not even having start-up we don't have it VRS operational. I think that's something you want to look at in a few years' time when VRS is fully operational and then you can look at the impact that MRS -- well, TTY and IPRS at that point in time.
4275 So I support that but I think -- I don't know how you would change it now when we don't know what the impact is of VRS without having VRS on the market.
4276 THE CHAIRPERSON: Do you have any data on how many -- on what your level of usage is on those, on IP relay and TTY?
4277 MS JONES-SHERK: I believe in the previous interrogatories we submitted all our comments for our IPRS service and our TTY service. So you have the data in front of you.
4278 THE CHAIRPERSON: Okay.
4279 MS JONES-SHERK: We could give you the -- you know, a point in time on the number of registered IP relay users we have but that may correlate and give you a sense of the number of minutes they are using for that service.
4280 THE CHAIRPERSON: And I know it's not necessarily representative of all potential VRS users and that sort of stuff, but it's good that we have that. So as much data as we have the less difficult it is. I was going to say easier but that's not the right word.
4281 Anybody else? Commissioner Shoan.
4282 COMMISSIONER SHOAN: Hello. Thank you for being here.
4283 I have a couple of quick questions. One of them is sort of an extension of the exchange you had with Commissioner Menzies with respect to Commission oversight of this potential third party administrator.
4284 You mentioned just a little earlier about having the administrator come to the Commission on an annual basis to get approval for funding which obviously is quite an effective hammer. I was thinking in terms of quality of service issues; complaints. Do you envision a role for the CRTC with respect to those issues too and just generally in terms of oversight?
4285 And I recognize obviously these are issues that you would want to discuss with other TSPs in this process but if you have any general notions or ideas about commission oversight over this third-party body?
4286 MR. DANIELS: I think the best parallel in this is again the CCTS which is the -- I guess I'm using the acronym and some people may not be aware of it, which is the telecom ombudsman that people can go to.
4287 The CRTC set up -- mandated that we set up the CCTS. We, a number of TSPs, got together and set it up initially. From that it moved to a permanent board so that the TSPs don't have control over it.
4288 The Board of Directors of that CCTS is totally focused on the performance matrix of the CCTS, how many complaints they have, how well it handles the complaints. There I'm talking about not the complaints about the TSP service. I'm talking about what happens at the CCTS itself when it receives a complaint, how quickly do they handle it, how quickly do they resolve it?
4289 There is all these metrics that the CCTS go through, even through their own call centre, how quickly do they answer or respond to complaints when people call up to say "I'm not happy with my service provider" how quickly does the CCTS answer the phone?
4290 All of that was looked at, at the Board of Directors sitting on it, and examined. A lot of attention was paid to it.
4291 Having said all of that -- so I think the Board was totally focused because the Board was worried about the service levels. Again, the TSPs who sat on it were worried about the fees and the rest of the directors were collectively worried about the service levels, but we all had a duty to look after the whole entity and look at it that way.
4292 Nonetheless, there was still a requirement to come back to the CRTC and report on how the CCTS has performed. We had a hearing about it about, I guess, it was two years --
4293 MS MORIN: Three years.
4294 MR. DANIELS: -- three years ago where we had a hearing where the CRTC looked at how is the CCTS performing, including hearing from the CCTS. And the CRTC generally, I think, found that the CCTS was performing very well but did order a couple of changes to its mandate and required some changes to its documents.
4295 And then I also believe that the CRTC ordered the CCTS to file annual information more detailed than had been historically been filed in order to do that which I believe the CCTS complied with.
4296 So that's the model. I think it worked very well.
4297 COMMISSIONER SHOAN: Okay. So the model essentially would be annual reporting with a periodic review every few years, much like the CCTS?
4298 MR. DANIELS: That's said much better than me.
4299 COMMISSIONER SHOAN: Okay.
4300 COMMISSIONER SHOAN: So one last question, and it's actually following up on a point you made very early in your presentation with respect to the Mission Consulting Report. You said you agreed with most of the report and virtually all of the recommendations but not all of them. I thought I would give you an opportunity to discuss what specific recommendations of the Mission Consulting Report you did not agree with.
4301 MR. DANIELS: The first one is we've generally -- I don't know if it's fair to characterize this but Mission puts out some options and I think Mission lays out what it would take to do a 24-hour in seven full roll-out.
4302 And our focus, as we just discussed, is we really think it's important to make sure that the Commission has a cap on the financing, not necessarily -- I'm not saying that we come every year but every few years they set the budget, they set what it is and that there be a cap and that the administrator has to work in with the cap for exactly the reasons that the Chair was describing in his questions to us.
4303 Mission doesn't take a position on that one way or another or, perhaps, some have interpreted Mission as saying, no, you need to do the full service regardless, but this is what it'll cost. So there we have a disagreement.
4304 The other thing that's actually more of a nuance, Mission proposes a board of directors and in the board of directors they are proposing that there be nine members of the board of directors, four of them from deaf and hard of hearing groups, three from TSPs and two from independent.
4305 We like that setup and the approach but we think that a board of nine is too big. We think it should be seven which matches the CCTS. And so we would take the deaf and hard of hearing groups from four down to three and we would take the TSPs from three down to two. The same structure, the same setup but just a smaller board.
4306 We think smaller leads to more cohesive, better decision-making, something that other agencies may have experience with.
4307 COMMISSIONER SHOAN: Those are my questions. Thank you.
4308 THE CHAIRPERSON: Thank you very much for a very thoughtful presentation and discussion. Enjoy the rest of the day.
4309 MR. DANIELS: We will now.
4310 THE CHAIRPERSON: We will take a five minute break.
--- Upon recessing at 1424
--- Upon resuming at 1430
4311 THE CHAIRPERSON: Order, please.
4312 Madam Secretary.
4313 THE SECRETARY: Thank you.
4314 We will now hear the Saskatchewan Telecommunications, who is appearing by videoconference from Regina.
4315 Please introduce yourself and your colleagues and you have 20 minutes.
4316 Also, I would ask that you please slow down your presentation. There are a lot of sign language interpreters here in the room. Thank you.
4317 MR. HERSCHE: For those of you who know me, slowing down may be the hardest part of my presentation.
4318 THE SECRETARY: I'm sorry, we cannot hear you. Just wait one minute. We cannot hear you.
4319 THE SECRETARY: Okay. Can you try?
4320 MR. HERSCHE: Can you hear us now?
4321 THE SECRETARY: No.
4322 MR. HERSCHE: It sounds like a commercial.
4323 THE CHAIRPERSON: Try it again. Say "Go, Riders, Go" or something.
4324 MR. HERSCHE: Oh, well, I assume you will all be here for the Grey Cup anyway, so I can say that to you then.
4325 You still can't hear us? No.
4326 THE CHAIRPERSON: We're still not quite getting it. If you can move that a little closer to you I think that would help.
4327 MR. HERSCHE: Okay. How about that?
4328 THE SECRETARY: No. We're going to --
4329 MR. HERSCHE: Is that better?
4330 THE SECRETARY: No. Just one minute.
4331 MR. HERSCHE: Gee, I think we had it earlier. I don't know if I should keep speaking here till you get the volume correct.
4332 MR. HERSCHE: They said they're not hearing us on that end.
4333 MR. SPELAY: Yeah.
4334 MR. HERSCHE: Is that better? We've turned up the -- she's turned up the volume considerably here.
4335 THE SECRETARY: Are you okay?
4336 MR. HERSCHE: So I assume we're --
4337 THE SECRETARY: Okay, you can start.
4338 MR. HERSCHE: Can you hear us?
4339 THE SECRETARY: Yes. You can start. Thank you.
4340 MR. HERSCHE: But you can hear us?
4341 THE SECRETARY: Yes, we can hear you.
4342 MR. HERSCHE: Okay.
4343 THE SECRETARY: We can hear you.
4344 MR. HERSCHE: Well, that's good. Thank you very much.
4345 MR. HERSCHE: Again, thank you very much for hearing us, Mr. Vice-Chairman, Commissioners. I am Bob Hersche from SaskTel's Regulatory Affairs, and with me today is Kevin Spelay, who deals with our disability and 9-1-1 issues.
4346 In talking to you today I will not reiterate all of SaskTel's involvement with the disabled over the past years. Everything from our higher practices, our work with provincial disability organizations, to our various provincial programs are all outlined in our previous comments in this proceeding.
4347 All I wish to point out is that as a Crown corporation we have remained cognizant of the needs of the disabled and have always acted to accommodate the requests of disabled residents in Saskatchewan.
4348 As an industry we have a myriad of programs for the disabled. If I could name just a few: MRS, closed captioning, text to 9-1-1 or IP relay for the deaf; TrueTone devices for the speech impaired; described video and special speaker phones for the visually impaired; equipment and training for the cognitively challenged; and Operator 168 and unique speed call systems for the motion impaired.
4349 THE CHAIRPERSON: Excuse me.
4350 MR. HERSCHE: I'm going too fast?
4351 THE CHAIRPERSON: Yes. Can you just slow down a little bit? It's tough for the --
4352 THE INTERPRETER: Hello. Could you please slow down, please?
4353 THE CHAIRPERSON: -- interpreters to keep up.
4354 MR. HERSCHE: Okay. Sorry about that.
4355 THE CHAIRPERSON: No problem.
4356 MR. HERSCHE: I said that will probably be the hardest part of my presentation. It's just built in my character somewhere.
4357 The industry also has a range of social programs to assist those with economic or social disadvantages, such as maintaining payphones or recycling cellular telephones for women in shelters. This is not to mention the range of public safety mechanisms being developed or proposed for both telecommunications and broadcast entities.
4358 I will not go on to name all the programs we support. Suffice it to say we have continued to go far beyond any accessibility measure outlined or even envisioned under any interpretation of section 27 of the Telecommunications Act's language suggesting that any carrier is subjecting the deaf to an unreasonable disadvantage or undue hardship.
4359 SaskTel is not protesting any of the measures that we've undertaken to this point. Unfortunately, despite our record in supporting persons with disabilities, we find ourselves in the uncomfortable position of not being able to responsibly support the adoption of a VRS project at this time.
4360 This difficult decision was taken after careful consideration of the record, which, in our view, does not provide a compelling case for VRS implementation. We seem to be replicating past initiatives established in other countries without due consideration of the new technologies being developed to assist deaf and hard of hearing persons.
4361 Just because the United States has developed this service a decade ago, it does not mean that we need to establish a Canadian service now.
4362 First and foremost, we readily admit to having no expertise in the delivery of a VRS service. The entire service, outside of Internet connections, has very little to do with telecommunications. We have read the Mission report, TELUS' assessment and the various responses put forward in this hearing process. These of course leave us with more concerns and uncertainty. I would like to share these concerns with the Commission and it is our hope that they will be considered in your final decision in this matter.
4363 In particular, we wonder how many people will actually be assisted with VRS and at what cost.
4364 Today SaskTel has only 320 deaf users registered through our various programs. This number has remained constant for a number of years. This being the case, the Mission report indicates that only 45 percent would use the VRS system due to a number of reasons such as lack of signing ability or that their communications needs are served by other means such as texting. This would leave us with a gross estimate of less than 150 people who would use a VRS system from our province.
4365 Assuming payments would be assessed in the same manner as the current high-cost service fund formula, a $30 million to $100 million per year Canadian VRS system could cost SaskTel some $1 million to $3 million per year, ad infinitum, for less than 150 users.
4366 I know that one of the top criteria for a VRS system put forth by the Canadian Hearing Society is the creation of "employment opportunities for Deaf people, sign language interpreters, and service providers." This is analogous to building more hospitals just to generate job opportunities for more nurses.
4367 Given the potential impact on jobs for deaf people and cost per user we can hardly say that this form of job creation is efficient or effective. From our perspective this is possibly the worst-case scenario. Unfortunately, the record of this hearing has not placated our fear that this is the direction we seem to be taking.
4368 This hearing is contemplating establishing a new institution which could be with us for at least the next 20 years, at a cost to Canadian consumers of telecommunications products of at the very least $30 million per year. Yet, the major benefits for the deaf remain ill-defined. The words and the intentions of the deaf can be distributed in a myriad of other ways -- cheaper, faster and better.
4369 Today the deaf can correspond with others through voice to text, directly online or through sign-to-sign using video such as Skype. There are literally hundreds of new applications for the deaf online and all indicators point to the fact that these applications are growing and improving daily. Consumers who are deaf or hard of hearing have a myriad of communications choices. Perhaps what may be missing is the education on how to use some of these options.
4370 In the TELUS trial, 70 percent of the calls made by trial participants were point-to-point calls between deaf or hard of hearing videophone users that did not require any sign-language interpretation. Videophone-enabled devices are extremely common today and would satisfy all of these point-to-point calls without a special VRS institution.
4371 Thus, given the limited number of overall number of users, the number of calls which truly require sign-language interpretation, the availability of alternative technologies and the projected cost of a VRS institution, I reiterate we are hard pressed to see the cost/benefit of this step or the balance when thinking of serving other disabled people.
4372 I have worked in the public service for decades. In my experience, once the Commission, or any other government agency, embarks upon the creation of a service such as VRS it is unlikely we will ever be able to shut it down regardless of the alternatives available and regardless of the availability of new technology.
4373 Like MRS and the new IP Relay services, numbers of users will continue to drop as easier, commercial alternatives become available. Yet, no one contemplates the removal of these programs even with the possible advent of VRS.
4374 Ten years ago VRS may have been a leading-edge concept necessary to enhance the lifestyle of the deaf. Today, with technological alternatives increasing at a prodigious rate, it is not. We are contemplating establishing an anachronistic program which we may not be able to curb, with a $100 million price tag.
4375 If VRS is mandated in Canada, SaskTel believes the Mission study proposal, which recommends that a single national VRS provider with the experience and expertise to offer a quality service, would be appropriate. The overall volume of business and the cost of operations would augur against the economics of each TSP operating their own service.
4376 Given that using tax revenues to fund this institution is a nonstarter, if VRS needs to be created, the model should be centrally funded, with revenues collected through a surcharge on network access services, including Internet access to recover the costs of providing VRS.
4377 If TSPs and ISPs are to become tax collectors for public policy goals, this surcharge should be transparent to Canadian consumers. Using the current Portable Contribution Fund as a mechanism to collect these funds from TSPs and ISPs would seem to be the most efficient and effective course of action. However, the base must be broadened beyond an assessment on individual NAS by TSPs.
4378 In Saskatchewan, if the same assessment base is used as MRS, the monthly assessment could go up to between 20 cents to 50 cents per subscriber depending on the overall cost of the system. It would also seem odd to use the Contribution Fund to finance training in universities for interpreters as opposed to telecommunications services.
4379 I'm sorry if I'm going too quickly.
4380 If VRS is mandated, SaskTel believes a phased-in approach, as recommended in the Mission study and as you've heard a number of times in the last two days, would seem to be most appropriate.
4381 According to the TELUS Final Report, "most of the VRS calls were placed during the day time, between 8 AM and 10 PM from Monday to Friday," with virtually no calls between midnight and 8 AM. There would need to be demonstrable demand before the VRS institution were to move to a 7/24 format.
4382 Finally, we must attempt to avoid the abuses so evident in the American VRS model. The Canadian model should not operate on a for-profit model which artificially creates need and usage in order to grow its revenues.
4383 The institution should have a board of directors made up of representatives from both TSPs and the deaf and hard of hearing community.
4384 Funding must be capped with the institution having to work within that budget. Many of the reports and interventions suggest that the cap should be $30 million. While we believe this may be excessive for the real demand for this service, we again recognize our lack of expertise in operating such an enterprise and defer to others as to a recommendation of the correct amount. However, it should have a cap at whatever limit is deemed appropriate.
4385 There should be a nominal charge to the participants of this service based on the length of time an interpreter is required. While we have limited experience in VRS, we have sufficient experience to know that a "free" service leads to abuse. Although we recognize that many of the deaf and hard of hearing also experience economic hardships, there must be some deterrent to using an interpreter for an inordinate length of time. This cannot and should not become a "chat" line. There are other less costly venues for this kind of interaction.
4386 As a conclusion, I suppose it is needless to say that SaskTel believes that creating a new VRS institution for Canada at this time would be inappropriate.
4387 VRS is neither efficient, nor effective in solving the communication needs of the deaf and the hard of hearing. It just provides another communications tool, but only for a select few that know sign language, and at great cost.
4388 New technology applications abound, there is little need for the interjection of the Commission at this point when the technological marketplace is serving the vast majority of needs of the deaf, but is clearly becoming more sophisticated in how it serves those needs.
4389 Anyway, thank you very much. Any questions you may have.
4390 THE CHAIRPERSON: Thank you.
4391 Commissioner Simpson will begin the questions.
4392 COMMISSIONER SIMPSON: Good afternoon, Mr. Hersche.
4393 I guess I can take my first question off of my list, which was to ask you if after listening to the record this week you had changed your position on the need for VRS.
4394 Just for point of clarification, if you don't mind, you in your presentation referred to the Portable Contribution Fund, which doesn't exist anymore. Are you referring to the National --
4395 MR. HERSCHE: The Canadian National --
4396 COMMISSIONER SIMPSON: Okay.
4397 MR. HERSCHE: -- Contribution Fund, yes.
4398 COMMISSIONER SIMPSON: Yes, which took over in 2011 I believe.
4399 MR. HERSCHE: Yes.
4400 COMMISSIONER SIMPSON: I guess I will go through your oral presentation first --
4401 THE SECRETARY: Sorry, Mr. Simpson, can you just wait one minute? Because I think there is a problem with your microphone.
4402 COMMISSIONER SIMPSON: Yes, we have a problem with my microphone I think.
4403 MR. HERSCHE: Yes, you are cutting in and out as you speak.
4404 THE CHAIRPERSON: We are fixing it. Just hang on.
4405 Madam Secretary, I think we have the easiest solution, is we will just swap chairs for a few minutes.
4406 And Commissioner Simpson will present himself behind Commissioner Duncan's sign for a few minutes. Other than that, it should work fine.
4407 COMMISSIONER SIMPSON: This seat is nice and warm.
4408 Mr. Hersche, I will go back to the question I had where we stopped.
4409 In your oral presentation just now you had made reference to essentially saying just because the United States has introduced VRS isn't necessarily a good reason why Canada should.
4410 And I could be mistaken in this notion, but I have been lead to believe that we are the only G8 nation left that doesn't have VRS. And I was wondering if you would like to comment on that?
4411 MR. HERSCHE: Sure. Yes, we follow the Australian example, the other examples as they go forward. Again, many of these items were pioneered, they were looked at with the FCC. And we are the first to say when that first started it was almost an essential service.
4412 Because others are adopting that, we have to look at this in a wider scope from our perspective in Canada that now the technology is changing in a very very quick timeframe.
4413 Some of the kinds of things that you are talking about or the Conexus report was talking about, while they say gee they are not really ready today. Given the pace of technological change, in two years they may be. And perhaps in less than that.
4414 We have seen the application and development of apps. They are just growing. I mean, you can go on the internet and you will see a page of new apps all the time for the deaf.
4415 So what we are really saying is we normally or we in many instances follow the lead of the United States in various institutions, in various kinds of...
4416 We shouldn't do that here. What we should be looking at is, where is technology going?
4417 And sorry, if I've gone on too long.
4418 COMMISSIONER SIMPSON: Thank you very much.
4419 Recognizing that SaskTel punches well above its weight with respect to technological innovation, I have seen your operation firsthand, I don't have any doubts that this is not because you don't embrace emerging technology or have an aversion to putting it to good use.
4420 But where I am going is taking your argument about economy of scale. Your figure that you had used, you had quoted 320 deaf users registered through your various programs. And I don't think I have a tremendous amount of difficulty with that figure, even if you do the Mission Consulting math on it and push it against the population of Saskatchewan.
4421 The number I come up with is probably somewhere between 600 and 700 profoundly or totally deaf people in Saskatchewan. And it looks like you have half of them.
4422 So my question is this though. It seems other carriers have recognized that emerging technology and the costs associated with it are trumped by their testimony this week that there is a social responsibility.
4423 And I would like you to tell the Commission which side you are coming down on. Is it that you are plagued with economy of scale and cost issues which force you to the position you are taking, or is it that there is a larger issue of you not accepting there is a social responsibility to at least consider this?
4424 MR. HERSCHE: That is two items, and if I can deal with them separately. Yes, we have a cost issue, there is no question about it.
4425 But I would like to, again from where I came from at one point, and I am an old policy wonk so you will have to forgive me. If the industry had $100 million today to provide, to work with disabled and to give access, would I give $100 million to the deaf? Would I make sure that others have access to other kinds of access?
4426 When we start to talk about unjust discrimination or undue preference, are we not in this one, to some extent, talking about undue preference for one group of disabled? And by the way, we are not saying we do not want to help the deaf. We have worked with the deaf organizations for...
4427 But we in SaskTel are dealing with a range of disabled groups, and we only have so many resources -- we have a social responsibility, but we only have so many resources to deal with them in an equitable manner.
4428 This may not seem to be that kind of balance.
4429 COMMISSIONER SIMPSON: But it is exactly, although you are not arguing economy of scale, is it not the issue of distance and difficulty in bringing services to all Canadians, you know, who through obligation to serve have, you know, the right to access to telecom services?
4430 Isn't this what the National Contribution Fund is for? And do you not see this as being a logical application to a group that cannot avail themselves for the services of a telecom?
4431 MR. HERSCHE: As we said in our presentation, we do see if you are going to mandate VRS that we would use the National Contribution Fund as the mechanism to do that. We are a little hesitant, if you will, that we would use the National Contribution Fund for non-telecommunications items, for example, training all sorts of people in sign language.
4432 Again, I am not sure that that was the initial intent as they do that. But again, I agree that the mechanism, if we are going to do this, should be the National Contribution Fund and, again, it should be something that goes across Canada.
4433 And I will be honest, we have argued that in other hearings for other issues as we go forward. So we really are consistent in that.
4434 We are just wondering at this point, before we rush into that, that we don't see -- right now we see such a range of potential expenses, we such a range of methodologies and we see, again in Saskatchewan, you name 600 people, but not 600 people would sign. We have talked to the Saskatchewan organization, very few sign.
4435 When you talk about the deaf and the hard of hearing, my mother is very much hard of hearing. All sorts of items, like -- but I am afraid at 84 she is not going to learn sign language. So she would be counted in that. And the number of people who would use this kind of service are actually much smaller.
4436 COMMISSIONER SIMPSON: Thank you very much.
4437 The figures you quoted, the range of potential costs on a per-NAS basis, I think you said it could range from .20 to .50 cents. Am I correct? I am pointing that out in my head. If those figures are --
4438 MR. HERSCHE: No, it is correct.
4439 COMMISSIONER SIMPSON: Okay. Would you sort of unpack for me how you arrived at those figures? Was that contemplating a national system and a tariff or a levy to all providers, including internet and cable? Where do you get that number from? How did you arrive at it?
4440 MR. HERSCHE: Well, we are basing it on the two vastly different estimates of cost; one is Sorenson, one for the Mission report. So that's our range. We personally could not cost that. And so all we're doing with that number is saying if we applied it to date exactly like we do the National Contribution Fund, this is the number we would get. If we have not calculated, if nationally we added -- which we are recommending, that you added internet services or if you added other kinds of services, if you added more -- for example, you're going to add more from the cable companies because of what kinds of -- they're not serving high-cost service areas, that kind of thing.
4441 So, these numbers may be -- they were just limited to under the current system that's what we would get.
4442 COMMISSIONER SIMPSON: M'hmm. In your presentation you had also referenced a surcharge for interpreter services. And again, I'm wondering if we can unpack that a bit. Are you inferring or implying that there should be a surcharge over and above that cost we've been talking about, which is passed back to the users? Is that what you were implying?
4443 MR. HERSCHE: Oh. No, I -- what I'm implying is that because of the costs of interpreters, lengths of time, you had an individual, who was before you yesterday, who talked about being online for -- or on a VRS-type system for a three hour conference call. If you are going to do those kinds of things, what we're saying is there should be a nominal, I'm not -- we're not saying full cost for the individual, but there's got to be some sort of nominal cost to go and use an interpreter and do those kinds of things when perhaps what you could use is Skype and just do it point to point with the other individual that you have there.
4444 COMMISSIONER SIMPSON: So you're saying that on point of principle. Have you scoped out any -- anything that could be instructive to us as to what that surcharge would look like as a percentage or a permanent cost?
4445 MR. HERSCHE: We have nothing to really base that on. We had long conversations, and we're talking about things like 5 to 10 cents a minute, something very nominal, but just that they know it's there.
4446 COMMISSIONER SIMPSON: Mmm.
4447 MR. HERSCHE: So we're not -- and by the way, that would be for a resident. I think if you're going to do something like that, you would have a different charge for a business if they wanted to -- to use that service, like we do in many other services that go forward.
4448 COMMISSIONER SIMPSON: M'hmm. Carriers have expressed that VRS is outside their area of expertise, and you've done a very good job of demonstrating that you believe that to be the case with your company, and that they should not really be held directly responsible for the provision of VRS services to their customers. In other words, there should be a tendered and contracted relationship. Where I'm going with this question is MRS is tariffed and yet they feel this is not an optimal approach for VRS. Do you agree with that view?
4449 MR. HERSCHE: I'm -- I wouldn't say totally in agreement with it. We do agree that the service should be placed in the hands of a third party. By a third party, I do mean very much like Bell is suggesting or Telus is suggesting as they -- as a separate organization, such as the CCTS [indiscernible]. What we are doing and where we vary somewhat with Bell is we would like -- if you mandate this, we would like the ability to put those charges that we would incur as a company into our MRS charge to our customers.
4450 So -- and I would like to address another issue, if you don't mind, since we're addressing MRS. Many of the discussions this afternoon said there was all this surplus in MRS. And maybe we are in the wrong area, but we don't have one. What we have is we do not spend all of the money we collect on MRS services, but essentially what we have is the other $250,000 that is in there goes to assisting and paying for some of the other services that we have for the disabled.
4451 So what we're kind of looking at is -- and MRS may not be the appropriate vehicle. We're not a hundred percent sure of that. But there should be some way of assessing what all of these costs are, not just the deaf or the other. To the customer. It should be the transparent customer that this is what you're paying for -- for these kinds of access services. And I think that's fair. It's like any kind of taxation or other kinds of things. We're asking our customers to pay for a social good. Whether we or many other customers -- or many other companies, I should say, kind of pass it through and they make more of a hidden charge, or they charge it upfront. We would like to see it charged upfront.
4452 COMMISSIONER SIMPSON: But just to clarify, though, you're saying that there are surpluses to cost but in your instance they're reallocated, so there are really no surpluses --
4453 MR. HERSCHE: Yes.
4454 COMMISSIONER SIMPSON: -- at the end of the day? So this figure that we're --
4455 MR. HERSCHE: That -- right.
4456 COMMISSIONER SIMPSON: -- so we're being given, in your experience or opinion is that 75 million -- does that position apply to all the 75 million as far as you're aware? Would you please restate your position as to --
4457 MR. HERSCHE: Okay. I --
4458 COMMISSIONER SIMPSON: -- outside your company's view?
4459 MR. HERSCHE: I do not ... I do not know what all the other companies do. I -- we have really not analyzed that, but internally in SaskTel we do -- we do bring in more money for MRS than we spend on MRS.
4460 COMMISSIONER SIMPSON: Hm.
4461 MR. HERSCHE: About two hundred and fif-- well, if I've got the right number here, $270,000. And so what we do do is we reallocate those costs to some of the other services. For example, toll discount operate at 168, the speed calling, 30, as an example. Those -- those are, again, things, services we give to the disabled, but we allocate the MRS dollars to them. Again, I -- sorry, I do not know what the other companies do.
4462 COMMISSIONER SIMPSON: But if there are surpluses, would you have a firm position against seeing some of those surpluses applied to VRS, perhaps to start-up costs?
4463 MR. HERSCHE: No, I wouldn't. I wouldn't see it as a problem. We -- we would be prepared to show where our -- our, let's call them surplus, I don't like to call them surplus because we do use them, but we can show where our dollars go. If there's any other --
4464 COMMISSIONER SIMPSON: Hm.
4465 MR. HERSCHE: -- dollars that do not go to the disabled --
4466 COMMISSIONER SIMPSON: Hm.
4467 MR. HERSCHE: -- I -- we would have no problems in allocating that to other disabled programs.
4468 COMMISSIONER SIMPSON: Okay. Thank you.
4469 Let's go back to the funding model for a second because what you are proposing is a bit of a variation on what we have been hearing from the other carriers. But I'd like to start by asking you your -- to clarify your position on the governance. We've heard from other carriers that a CISC model is problematic because it requires consensus, whereas a board model, it's a little more manageable, like CCTS. Do you have a view on that?
4470 MR. HERSCHE: Yeah, we -- again, we have been listening and talking about this, and we -- I would not favour a CISC model. We do like the position that Bell took in terms of starting with an administrative consortium in order to get some of the kinds of information, an RFI, what kinds of things they could do, and then going into a research stage. And finally, as I mentioned earlier, we do like the idea of a board that would oversee this, very much like the CCTS. Right now my understanding is the CCTS has -- you know, there would be, say -- rather than four consumer groups you'd have four from accessibility groups, three from the industry, and two people independently that really know how to run organizations and do --
4471 COMMISSIONER SIMPSON: Mmm.
4472 MR. HERSCHE: -- do this in an efficient manner.
4473 COMMISSIONER SIMPSON: On the issue of who pays, would you tell me your position on why the carriers would not be able to absorb the cost of VRS? I'm asking this in context to your -- in the economy of scale issue we talked about earlier, but I'd ask you to also consider in your answer that there's a different economy of scale and this is a national program that would help defray some of the issues you have.
4474 MR. HERSCHE: First let me give you an example. We don't run our own MRS program. We contract it out to Telus. Telus is able to give us some economies of scale. So we would -- we contracted out to them. Again, ourselves in terms of running of a VRS program, frankly we could not do it ourselves. We're a fairly small organization on a relative basis. But if we were doing an assess-- we were assessed a certain amount on the contribution fund, that amount of money went into a central payment, then I think you would end up with a national one, hopefully one service provider that provides both English and French. And that service provider, by doing those, would -- or could hopefully come up with some economies of scale in term-- that the board of directors would do that. They would also come up with some economies, again I go back to I think the amount that we are giving to them should be capped.
4475 COMMISSIONER SIMPSON: We had heard throughout the week inferences, I believe it was Telus, who alluded that if we were to determine that this was to be a percentage of revenue-based fund, that while costs may not get passed directly through to all consumers, there might be a recognition of an increase in overall cost that may ultimately end up altering in some amount the cost to all consumers. Do you have a position as to -- given that you have said there's a 20 to 50 percent issue that you would be dealing with, but is there an amount you have in your mind --
4476 MR. HERSCHE: [indiscernible]
4477 COMMISSIONER SIMPSON: -- is there an amount you have in your mind that would be an acceptable threshold for an increase on a national level to customers?
4478 MR. HERSCHE: By the way, just one correction. It wasn't 20 to 50 percent, it was cents.
4479 COMMISSIONER SIMPSON: Cents.
4480 MR. HERSCHE: Not per. Yeah. [indiscernible]
4481 COMMISSIONER SIMPSON: Yeah. Sorry, my -- if I said "percent", my apologies. You can sit down now.
4482 MR. HERSCHE: But ... I would like to go back and I'm sorry if I harp on this a little bit, but you say what's an acceptable -- and I find, and this is a personal thing, I have nothing to base it on, but if we were going to make such a service a hundred million dollars, I think that may be unacceptable to the consumers and -- and to the industry as we begin to do this. Again, I look at that not so mu-- because I still -- as I said before, we still look at our social responsibility. But if I spend a hundred million dollars on one group, what do I do in terms of my other social responsibilities as I begin to -- to do those forward? So what you're doing is -- is really extrapolating some of those kinds of things. So ...
4483 And if we -- and I go with -- with some of the other comments that you have received. To some customers 10 cents may be too much. For some customers 15 cents may be too much, but what I would like to say is -- is, you know, the extreme over there is easier to talk about. Then is $30 million -- I think in $30 million that we could as an industry begin to absorb that. And by absorbing that, I say that we're all running businesses, it all goes to the customers some way or other, as -- there's no, gee, the company will absorb it a hundred percent. It just doesn't work that way.
4484 COMMISSIONER SIMPSON: Uh-huh. So there isn't a threshold that you have in mind that you could offer up?
4485 MR. HERSCHE: No.
4486 COMMISSIONER SIMPSON: Okay. You had referenced a made in Canada solution and I'm thinking now about administration. If we have, as you suggested, an entity that is built on your -- the vision of your model, would the administrator be the one with the contractual relationship with the VRS provider or would they simply have oversight to that provider and would the carriers have a direct contract with the PRS provider?
4487 MR. HERSCHE: I -- again, I have to support Bell and Telus in some respects on that, that the board itself would have the contract. I do like the idea that -- that the board would hold -- or that the platform, if you will, would -- would be a generic or that the board itself, the institution itself, will hold a licence. One thing you -- just normal business, whether it be VRS or -- or any other kind of business, you don't want to be held hostage by that service provider, that he or -- or that company would be the only person who could ever provide that kind of service for you. So I think the board has to be -- they will do the selection, they're going to guide it, they're going to see where the changes need to -- need to happen.
4488 COMMISSIONER SIMPSON: Does that view, and acknowledging that you're not an expert in this area, but does that view in any way limit the scope of who can respond to an RFP? I'm thinking here that some providers who are expert in the area bring with them proprietary technology. And does that have any downsides that you're aware of?
4489 MR. HERSCHE: You're -- again, we have not talked about this very much, but, yes, it would limit to some extent. When MTS this morning was talking about Australia using something like Skype or other kinds of broad platforms, it may limit the platform, it does not limit the service provider who can do this, but it may limit someone who has proprietary technology. Again, I'm -- I'm a little hesitant to become captive of any one technology or provider because, as I go -- said in our -- our remarks, we're looking at a long term, 20, 25 year institution. Technology is going to change numbers of times as we go forward on that.
4490 COMMISSIONER SIMPSON: You support a cap of $30 million. Is that exclusively because it's a figure that has been arrived at by the Mission Consulting study or is that something that you're arriving at through your own determination? And if so, why?
4491 MR. HERSCHE: No, it ... Yeah. It's -- it's essentially through the -- the Mission. And -- and really the 30 million dollar cap is -- that we suggested is more of -- rather -- it's more as an example, that there has to be a cap of some sort. Because I think you mentioned, when talking to Bell, we have to make sure this isn't a runaway train. We have to make sure that this is the -- the kind of system that we -- we can control. You may change, you, the CRTC, may change the cap over time, but you just -- we just can't have carte blanche.
4492 COMMISSIONER SIMPSON: Do you have any views as to how the cap should be implemented?
4493 MR. HERSCHE: I'm not sure what you mean by that.
4494 COMMISSIONER SIMPSON: Is it --
4495 MR. HERSCHE: You mean --
4496 COMMISSIONER SIMPSON: Is it tied to --
4497 MR. HERSCHE: Value?
4498 COMMISSIONER SIMPSON: Is it tried to a framework of -- of phasing in so that it promotes a learning experience that can help determine whether that cap is realistic?
4499 MR. HERSCHE: Some of the items in the Mission report, what that cap should be in realistic terms is once an administrative consortium does the RFI, looks at what kinds of level of service that should be provided, and again we suggested that -- that there should be a start of a more minimal kind of service to see what this -- how many people are actually using this and what for -- what are --
4500 COMMISSIONER SIMPSON: M'hmm.
4501 MR. HERSCHE: -- they using it for, so I think it should be deve-- I'm not suggesting that you should today, if you were to mandate VRS, say, oh, the cap will be X. Let the system come to you, the admin consortium, and say this is approximately what we think it should be and why.
4502 COMMISSIONER SIMPSON: M'hmm.
4503 MR. HERSCHE: We don't ha-- again, I go back and I -- sorry. We just don't have the expertise to calculate that as it goes forward.
4504 COMMISSIONER SIMPSON: Just prior to your appearance Bell had taken a fairly large step forward with some recommendations on phase-in. And off the top of your head, if you -- did you have an opportunity to hear their testimony today?
4505 MR. HERSCHE: Yes, I did.
4506 COMMISSIONER SIMPSON: Do you have any views as to their recommendations on their notion that a 1 million dollar amount of money, approximately, I haven't got my notes, they're over with Commissioner Duncan, but that there was an initial $1 million of research phase followed by a 4.1 million dollar second phase? Is this something that assuages your concerns at all? In terms of what that cap should be.
4507 MR. HERSCHE: Again, I -- that was the first I've -- I've heard their numbers, but they seem reasonable, if you will, to start.
4508 COMMISSIONER SIMPSON: Okay, thank you.
4509 As part of containing costs at the outset, because you've said that this is a bit of a journey into the unknown with respect to what financial and technology and human resources are going to be required to get it up to full speed, you had suggested that a limited service be at least initially available, and you suggested a 6:00 a.m. to 10:00 p.m. service time, I believe. What is your position with respect to 911? The trial that Telus did had indicated that 911 service would not be available to the trial users. Is this something that you would also suggest, that any VRS users be reliant on other means to contact 911 during that limited period?
4510 MR. SPELAY: I don't think we would ever necessarily say that. If -- if it is their best available means to contact 911, then -- then that should be their means to -- to contact them. There --being an access independent VoIP-type services, what this will end up being --
4511 COMMISSIONER SIMPSON: M'hmm.
4512 MR. SPELAY: -- they will not have any location information. So we would, if they were requiring location information, use the text to 911 service that's being developed.
4513 COMMISSIONER SIMPSON: So this leads me into a host of 911 questions we've been asking. So in your operator-assisted services, in a VRS world do you envisage that the VRS intermediary be able to call the PSAP directly or would they require the services of your operator assistance?
4514 MR. SPELAY: Currently today for our 911 access independent VoIP services we use an intermediary. We don't presently use our own operator services.
4515 COMMISSIONER SIMPSON: Yeah.
4516 MR. SPEALY: There's no reason that they could not use our intermediary or become the intermediary themselves for this solution and receive the same numbers for access to the piece to offset we give.
4517 COMMISSIONER SIMPSON: Yeah. And a bit of a housekeeping question: What is your position on whose responsibility it is for consistent location information in this VRS application? Whose responsibility, the VRS provider, you or the user?
4518 MR. SPEALY: Ultimately it ends up being the user that would need to provide us that information. We are unable to map an IP address to an address, as you probably are well aware.
4519 So there would be no way that the VRS provider could do the same. So it would ultimately end up on the end-user as they move or have the possibility they're going to move.
4520 COMMISSIONER SIMPSON: Okay.
4521 I just have, I think, two more questions and then I'll turn it over to my other Commissioners.
4522 In the catchment of a central fund, if internet revenue is captured in this central funding should the existing contribution -- I'm thinking of intercarrier payment processes -- be followed?
4523 MR. HERSCHE: I think the existing contribution processes would be followed. Adding internet into that calculation would be fairly easy. We already record it as we go forward.
4524 So it's just a secondary kind of calculation, one for high-cost service areas and one for -- it would be for VRS.
4525 COMMISSIONER SIMPSON: Okay. And on the issue of technical and customer care what is SaskTel's view being that you are part of the provision process to the customer base?
4526 What's your view as to who handles technical assistance and the broader issue of education and overall customer care? Is that the responsibility of the VRS provider or do you share that responsibility with them? What's your view?
4527 MR. SPEALY: I believe if they are an internet customer of ours you would definitely have a large share of the troubleshooting and technical issues to ensure that their internet service is working to a level for VRS.
4528 The actual VRS system, however, as it would be an independent third party we wouldn't have -- we wouldn't be able to see into that system necessarily so we would have to either work in conjunction or pass that on if the internet connection was found to be fine.
4529 COMMISSIONER SIMPSON: M'hmm, okay.
4530 Thank you very much. Those are my questions.
4531 THE CHAIRPERSON: Commissioner Shoan...?
4532 COMMISSIONER SHOAN: Thank you. Good afternoon.
4533 I have a few, just a couple of quick questions following your presentation today.
4534 You stated in your presentation that once the Commission or any other government agency embarks upon the creation of a service such as VRS it is unlikely we will ever be able to shut it down regardless of the alternatives available and regardless of the availability of new technology.
4535 Prior to your appearance we had a conversation with Bell about mechanisms that could be in place to hold a third-party administrative agency implementing VRS accountable. One of the mechanisms that Bell noted was something similar to that which has been imposed on the CCTS, namely annual reporting and periodic reviews of an organization's mandate and effectiveness.
4536 Do you not feel that if mechanisms such as that were imposed on a potential third party VRS administrator that would alleviate some of your concerns that this would be, as you've noted or potentially noted, a 25-year project?
4537 MR. HERSCHE: The short answer is no.
4538 The reason I say that is while you would do the review every three years, five years, however you wish to do that, while you may give them direction in terms of you could do the system better, you could change, these kinds of things, I would suggest and again this is built on being an old guy essentially, that I've never seen someone who would say, "You're going to shut this down. You're going to take those clientele that you have made dependent on this service and you will shut it down". You will never be able to shut it down when you do that.
4539 Never may be a long time but it will be quite a horrific process to try to withdraw from that once you put that in. Now, perhaps you could institute another institution or something else but you can't get rid of the VRS institution itself.
4540 COMMISSIONER SHOAN: Okay. Thank you for that.
4541 I take your point that you raise in your presentation with respect to the potential cost of the implementation of a VRS service in the sense of there was a great deal of unknowns with respect to how much it would cost.
4542 Do you not feel that if the type of -- for example, of a research phase advocated by Mission Consulting or perhaps the Phase A suggested by Bell, if either of those approaches were implemented that it would provide a level of clarity with respect to information?
4543 And I'm thinking namely about demand for a VRS service that once that initial information had been gleaned after a two or three year phase that the cost would crystallize in such a way that it would be far more of a system that's reflective of the demand of the deaf and hard of hearing in Canada and that the cost may not necessarily be as grandiose as those proposed, for example by Sorenson?
4544 MR. HERSCHE: Oh, yeah, no issues with that. I think that's one of the things that we started in our presentation, is from all of our readings, and again we're not experts -- from all our readings we didn't have the kind of certainty or there is nothing I would build -- and I have gone in other things -- that I would build a business case on.
4545 This research phase that's something I think we have to do and get these RFIs out there. That would give a lot more of a structure in the next couple of years of what we're actually dealing with on this and perhaps we're -- that will give a better idea also of not only just the volume of wants but what is the volume of needs in terms of what is really needed to satisfy some of the needs.
4546 Again, sorry if I go on for a moment but I listened. I have been listening to this hearing and I go by the one instance, the one lady who said, "I had to take a day off work and my installer didn't come". Every one of my staff have experienced that at home. I can't -- that's not the kinds of reasons that we need to do VRS.
4547 What we need to do is say why do we need VRS? Be a little bit more defined of doing that. It's not just the inconveniences of the day. What is necessary in terms of their access to the economic and social good, making them more equal within Canada. I'm okay with that.
4548 It's just where -- again, I'm looking for parameters is what we're really saying.
4549 COMMISSIONER SHOAN: That's fair.
4550 MR. HERSCHE: The research phase that they talk about is great.
4551 COMMISSIONER SHOAN: Great. I can very much appreciate your response.
4552 Those are my questions, Mr. Chair. Thank you.
4553 THE CHAIRPERSON: I just have one very little one that I wanted to touch on again. It's regarding MRS and its future. I'm intrigued by this practice of obtaining a tariff for one purpose and using it for another.
4554 I just wanted to know if what you were saying when you wanted to move the money that is not being spent on MRS that you're collecting through the MRS tariff to cover off any obligations for VRS, how would that work, particularly given that I think you took the position -- and I might have misunderstood -- that you think VRS revenues should be collected from internet operations as well.
4555 MR. HERSCHE: Yes, it should be. But these rates for MRS were established some time ago and there is a differential. There is no question. There is a differential between what TELUS is now charging us to deliver that service and what we are collecting from our various tariffs.
4556 So I have two options at that point. I can bring it into the -- I can bring it into the company and it would disappear somewhere and that would be my profit margin, I guess, or whatever you would want to call it. Or I could make that -- put that money towards similar services, the same kinds of things that I already have for disabled and, you know.
4557 So it's used for the purpose that -- again, the social purpose that it was defined for in the first place.
4558 THE CHAIRPERSON: I don't quite understand that. I was trying to get at --
4559 MR. HERSCHE: Sorry.
4560 THE CHAIRPERSON: I was trying to get at -- you mentioned and maybe I misunderstood. You mentioned that you thought that that differential -- I think we can agree on that term -- between the money spent on MRS and the money gathered, you wanted to be able to apply that to any obligation you might have through VRS? Or did I misunderstand?
4561 MR. HERSCHE: We currently -- today our MRS fee is 15 cents per month per wireline residential telephone user. Out of that 15 cents a month we collect, we today put that money towards paying for our MRS and IP relay services.
4562 And if there is a surplus --
4563 THE CHAIRPERSON: Well, you said there was --
4564 MR. HERSCHE: -- or a differential today --
4565 THE CHAIRPERSON: You said there was a $250,000 one.
4566 MR. HERSCHE: A differential, yes, and there is and we apply that today to other programs that we do for disability.
4567 THE CHAIRPERSON: Right, okay. What I'm trying to get around to -- yes, you want to take that instead and move it to a VRS. Is that right?
4568 MR. HERSCHE: We would like to --instead we would raise that fee. We would be allowed to raise that fee and to pay for our VRS contribution.
4569 For example, if today we spend 15 cents and our assessment would come to, let's pretend, 20 cents more -- 20 cents per subscriber including all my revenues from internet and telecommunication services, while I like the idea and we support the idea of a central fund, that money that now goes from SaskTel to that central fund, I would like to be able to increase my MRS fees by that amount.
4570 So I can again use the money I'm collecting for MRS or let's not call it MRS now. Let's call it for access services and I would distribute it to pay for those access services including MRS and VRS.
4571 THE CHAIRPERSON: Okay. Have you thought about how much that differential might change if, like according to the Sorenson submission, in the U.S. after VRS was introduced, demand for TTY service went down by 87 percent and demand for IP relay went down 51 percent which would really leave you with about -- oh, given your stats it would leave you with 50 or 60 people maybe still using that service.
4572 Don't you think it would be appropriate to review the MRS tariff at that point because if that's costing you 15 cents per subscriber right now and for 300 people, it's not going to cost you 15 cents a subscriber for 60 people.
4573 MR. HERSCHE: Agreed. What we would have -- I would have no problems in reassessing what we would do with that differential between what we're paying for MRS today or under a VRS system, how much would go to VRS and how much would go to other disabled programs.
4574 Again, what we're saying is that's just not -- that's just not free money today that is out there. There may have to -- there may have to be an increase in those fees to pay for both MRS, VRS and other social obligation access services.
4575 THE CHAIRPERSON: Thank you. I think we can all agree we're talking about other people's money.
4576 Thank you very much for your presentation today.
4577 MR. HERSCHE: Thanks.
4578 THE CHAIRPERSON: And I hope you enjoy the rest of the day.
4579 Thank you. That concludes our questions.
4580 MR. HERSCHE: Thank you very much. Bye.
4581 THE CHAIRPERSON: Legal, questions...?
4582 No questions.
4583 We will adjourn for the day. Thank you very much, everybody, and reconvene at nine a.m. tomorrow morning.
--- Whereupon the hearing adjourned at 1539, to resume on Thursday, October 24, 2013 at 0900
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