ARCHIVED - Order CRTC 2000-17

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Order CRTC 2000-17

Ottawa, 19 January 2000
File No.: 8665-C12-06/98

1.

In 50% Discount for TDD users on long distance calls for hearing or speech-impaired subscribers, Telecom Public Notice CRTC 98-30, 7 October 1998, the Commission expressed the preliminary view that calls originating from a business line dedicated to a telecommunications device for the deaf (TDD) user and billed to the business, should be eligible to receive the TDD discount, and that the eligibility criteria should be the same for all former Stentor-member companies, specifically BC TEL, TELUS Communications Inc., Bell Canada, Island Telecom Inc., Maritime Tel and Tel Limited, MTS Communications Inc., NBTel Inc. and NewTel Communications Inc. (the companies).
Background

2.

The Commission first approved the 50% discount on long distance calls made by customers requiring the use of a TDD in Bell Canada, General Increase in Rates, Telecom Decision CRTC 80-14, 12 August 1980. The TDD discount recognizes that a hearing or speech impaired customer using keyboard-type equipment requires more time to transmit and receive a message than a non-impaired customer communicating orally. The Commission approved the TDD discount in an attempt to equalize communication costs between hearing or speech impaired customers and other customers. In subsequent years, the discount was extended to the other former Stentor-member companies, albeit with some differences in the eligibility criteria among the companies.

3.

The TDD discount is available on long distance calls rated pursuant to the companies' basic toll schedule. Toll discount services, such as Advantage, are not eligible for the TDD discount, but the rates for toll discount services are generally not far removed from basic toll rates, discounted by the 50% TDD discount.

4.

At present, the criteria to determine eligibility for the TDD discount differ among the companies.

5.

The Commission received comments or reply comments from the Canadian Association of the Deaf (CAD); Centre québécois de la déficience auditive (CQDA); the British Columbia Coalition of People with Disabilities; and Stentor Resource Centre Inc. (Stentor) on behalf of the companies.
Issues raised by parties

6.

Stentor submitted that, in light of changes in technology, regulation and the highly competitive nature of the long distance market, there is no need to change the present eligibility criteria for the TDD discounts. Moreover, according to Stentor, the development of alternative ways of communicating, such as e-mail, faxes, and the Internet, continues to improve accessibility for the hearing or speech impaired and calls into question the need to broaden the existing eligibility criteria for the TDD discount.

7.

Stentor submitted that in the current competitive market environment the costs of widening eligibility for the TDD discount would rest on the companies' shareholders or long distance customers.

8.

Stentor also submitted that business customers may abuse the TDD discount by routing ineligible calls over lines eligible for the TDD discount. Stentor argued that the Commission does not have the resources to prevent such abuse.

9.

Accordingly, Stentor submitted that the Commission should not mandate the provision of the TDD discount to business customers.

10.

CAD submitted that use of the telephone companies' message relay service is increasing, even though alternatives such as e-mail and faxes are now available. CAD and CQDA stressed the employment and other economic benefits to the speech or hearing impaired if the TDD discount were available on business lines dedicated to hearing or speech impaired employees. They supported expanding eligibility for the TDD discount to include business lines, since the hearing or speech impaired experience difficulties communicating with telephones whether they are at home or at work.

11.

CAD and CQDA also submitted that the former Stentor-member companies should use common criteria to determine eligibility for the TDD discount, since the hearing or speech impaired throughout Canada experience the same difficulties in communicating over the telephone network. Neither CAD nor CQDA expressed their views on the appropriate common criteria for eligibility for the TDD discount.
Conclusions

12.

The Commission considers that business lines dedicated to hearing or speech impaired employees or provided by businesses to serve hearing or speech impaired customers should be eligible to receive the TDD discount, and that the same eligibility criteria should apply to all former Stentor-member companies.

13.

While some parties suggested that in some instances businesses might abuse the TDD discount by routing ineligible calls over lines eligible for the TDD discount, the Commission considers that such abuse is unlikely to any degree. The TDD discount would be available only on calls rated pursuant to the basic toll schedule. The many business customers that use discounted toll services would not find it worthwhile to abandon these services in favour of services rated pursuant to the companies' basic toll schedule solely to secure the TDD discount. The Commission also considers that any revenue reductions associated with extending the discount to dedicated business lines would be minuscule.

14.

The Commission therefore directs the former Stentor-member companies to make the 50% TDD discount available on the following calls rated pursuant to the companies' basic toll schedule:

(1) all calls within Canada that originate from and are billed to the residence service of a registered or certified hearing or speech impaired TDD user;

(2) all calls within Canada that are routed through or by a message relay centre or service;

(3) all calls within Canada billed to the calling card of a registered or certified hearing or speech impaired customer;

(4) all calls within Canada that are made from dedicated lines used by registered or certified hearing or speech impaired TDD users at their place of employment and billed to the employer; and

(5) all calls within Canada made from a dedicated line leased by a business to offer TDD services to its customers.

15.

The companies are ordered to issue revised tariff pages reflecting this order within 21 days of the date of the order.
Secretary General
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