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Ottawa, 11 January 2011

File No.  8665-C12-200807943


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 –Amendments to the
22 December 2010 Letter Due to Further Requests for Extensions

Dear Madam or Sir: 


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, were 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 had sought extensions to the IP relay launch date set in that regulatory policy. TELUS Communications Company (TELUS) and Bell Aliant Regional Communications, Limited Partnership (Bell Aliant), Bell Canada, KMTS, NorthernTel, Limited Partnership and Telebec, Limited Partnership, (collectively, the Bell Companies) 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. In addition, many LECs had chosen to use TELUS or the Bell Companies as their wholesale IP relay provider; as a result 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.

22 December 2010 Letter

In a Letter dated 22 December 2010, Commission staff


Since the issuance of the 22 December 2010 letter, other LECs have requested extensions to the launch dates of their own retail IP relay service for the same reasons as those set out in the 22 December 2010 letter.

In addition, prior to the release of the 22 December 2010 letter, Quebecor Media Inc., on behalf of Videotron, DERYtelecom and La coopérative de la câblodistribution de l’arrière-pays, each submitted that they would not be able to launch their respective retail IP relay before 1 March 2011, which were not addressed in that letter.

Analysis and conclusions

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 extensions requested at that time.

With respect to the requests for further extensions due to the ongoing technical issues, Commission staff is concerned about the lengthy delay in rolling out IP relay service; however, Commission staff considers that the parties are actively working towards the full implementation of IP relay and that the requested extensions set out above and in the 22 Dec 2010 letter are appropriate and necessary. It is expected, however, that LECs will provide high quality IP relay service as soon as possible and by no later than the dates specified above, and 30 April 2011 where not otherwise specified.

Commission staff further notes that, as set out in the Commission’s 25 June 2010 letter, the Commission has, among other things, (a) required all incumbent LECs (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; (b) directed 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; and (c) required all LECs to report to the Commission via letter once they are providing access to IP relay services to their retail customers. Commission staff notes that these requirements continue to apply.



Martine Vallee
Social and Consumer Policy

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