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Ottawa, 22 December 2010

File No.  8665-C12-200807943

BY EMAIL

Interested Parties to Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430

Re:  Implementation of Internet Protocol (IP) Relay Services – CRTC Determination on Further Requests for Extensions by Several Telecommunications Service Providers

Dear Madam or Sir: 

Background

In Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430 (RP 2009-430), 21 July 2009, the Commission ordered that all local exchange carriers (LECs), including wireless competitive local exchange carriers (CLECs), and voice over IP (VoIP) providers that are required to provide Teletypewriter (TTY) Relay to provide Internet Protocol (IP) Relay service by 21 July 2010.  The Commission allowed parties to satisfy the obligation to provide IP Relay by providing the service directly or by outsourcing the provision of the service to a third-party.

Several LECs have sought extensions to the IP relay launch date set in that regulatory policy.

  • TELUS Communications Company (TELUS) and Bell Canada argued that they needed more time to launch their respective retail and wholesale IP relay services to ensure the service provided would be robust and high-quality.
  • Many LECs had chosen to use TELUS or Bell as their wholesale IP relay provider; as such, an extension of the wholesale launch led them to request an extension for their retail launch.

The Commission solicited comments on these requests and, after considering the submissions, granted the requested extensions.

In a letter dated 25 June 2010, the Commission, among other things, extended the IP relay launch date for TELUS to 21 September 2010 and for all other LECs until 31 December 2010.  The Commission also set out the following reporting requirements:

  • “TELUS is to update the Commission on the progress of its retail and wholesale IP Relay service offerings via status reports, to be filed every 30 days, beginning 31 July 2010 until 31 December 2010”; and
  • “All LECs that are not using TELUS as their underlying IP Relay provider are to update the Commission on the status of their respective retail and/or wholesale IP Relay service offerings via status reports, to be filed every 30 days, beginning 31 July 2010 until 31 December 2010.”

TELUS has since launched its retail and is in the process of launching wholesale IP relay service.

Submissions

Several LECs, all of which will be using TELUS or Bell as their wholesale IP relay provider, have written to the Commission requesting further extensions for their IP relay launch, past 31 December 2010 due to technical issues related to the wholesale service.

  • Bell Canada and Bell Aliant have requested an extension until 30 January 2011 for their retail IP relay launch.
  • MTS Allstream has requested an extension for implementing wholesale IP relay until 31 March 2011 (end of first quarter of 2011).
  • Bell also requested an extension on behalf of KMTS, NorthernTel, Limited Partnership, and Télébec, Limited Partnerships until 1 March 2011.  
  • Northwestel has requested an extension until 1 March 2011.
  • TBayTel has requested an extension until 30 April 2011.
  • The Ontario Telecommunications Association has requested an extension until 30 April 2011 on behalf of its members[1].

The Bell Companies also submitted that they expect that their wholesale customers may require up to 90 days after the wholesale services are implemented to provide their own IP Relay services to customers. 

To date, other TSP/LECs have not requested extensions and are assumed to be on track to launch their retail IP relay before 31 December 2010.

Analysis and conclusions

Commission staff notes that, in its 25 June 2010 letter, the Commission stated that it is important that high quality relay services be made available to Canadians as quickly as possible; however, due to the unanticipated technical challenges that have arisen in the roll-out of the service, it was appropriate, given the circumstances, to grant the requested extensions. Commission staff notes the submissions by these parties that, due to the ongoing technical issues, the extensions are necessary to ensure the delivery of high-quality service.

Commission staff is of the view that the extensions to the deadlines for the launch of IPRS requested by LECs as set out above are appropriate. 

Commission staff notes that the above-noted reporting requirements, as set out by the Commission in its 25 June 2010 letter, remain in effect. Further, as set out in that letter, the Commission:

  • Requires all incumbent local exchange carriers (ILECs) who filed proposed tariffs for their IP Relay service, to file proposed tariff amendments reflecting the revised effective date of the service no later than 30 days before the proposed effective date.
  • Directs all large and small ILECs who have not yet filed tariffs for IP Relay service, to file proposed tariffs no later than 30 days before the proposed effective date of the service (i.e. 31 March 2011).

Sincerely,

ORIGINAL SIGNED BY MARY-LOUISE HAYWARD on behalf of:

Martine Vallee
Director, Social and Consumer Policy

cc:  Distribution list

Distribution list:

Bell.regulatory@bell.ca ; regulatory.affairs@telus.com ; regulatoryaffairs@nwtel.ca ; reglementa@telebec.com ; document.control@sasktel.sk.ca ; iworkstation@mtsallstream.com ; regulatory@bell.aliant.ca ; mworkman@blindcanadians.ca ; p_gordon@rogers.com ; Jroots@cad.ca ; mpotvin@ccbnational.net ; arendall@cogeco.net ; gmalkowski@chs.ca ; jbentley@chs.ca ; dfels@ryerson.ca ; judo@ryerson.ca ; cqda@videotron.ca ; tjgreen@bellnet.ca ; cathy.moore@cnib.ca ; ccd@ccdonline.ca ; bxt1@nbrscanada.com ; info@raaq.qc.ca ; gkane@stikeman.com ; hardy63@live.com ; andres@isptelecom.net ; regaffairs@quebecor.com ; gcordeau@maskatel.qc.ca ; regulatory.matters@corp.eastlink.ca ; brenda.stevens@rci.rogers.com ; regulatory@telnetcommunications.com ; s.cloutier@axion.ca ; regulatory@sjrb.ca ; regulatory.aff@fidomobile.ca ; michel.messier@cogeco.com ; regulatory@vianet.ca ; sbishay@iristel.com ; ataylor@personainc.ca ; info@mountaincable.net ; lcundy@telus.net ; documents@accesscomm.ca ; jboutros@globility.ca ; regulatory@bell.aliant.ca

[1] Brooke Telecom, Bruce Telecom, Cochrane Telecom, Dryden Municipal Telephone System, Execulink, Gosfield North Communications, Hay Communications, Huron Telecommunications, Lansdowne Rural, Mornington Communications, Nexicom Telephones, North Frontenac Telephone, North Renfrew Telephone, Ontera, Quadro Communications, Roxborough Telephone, Tuckersmith Communications, Westport Telephone and Wightman Telecom