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Ottawa, 26 July 2011

File No.:  8665-C12-200807943

To: TELUS, Rogers, CAD

By email: regulatory.affairs@telus.com; brenda.stevens@rci.rogers.com; Jroots@cad.ca; info@cad.ca

Re:  Letter from the Canadian Association of the Deaf concerning the implementation and quality of Internet Protocol Relay Service (IP relay)

Dear Madam, Sir:

The Commission is in receipt of a letter by the Canadian Association of the Deaf (CAD), dated 2 June 2011 (attached), in which it expresses concerns regarding the implementation and quality of Internet Protocol Relay Service (IP relay service). CAD raised concerns regarding (a) the quality, functionality and design of IP relay service and (b) the steps taken by TSPs to date to promote the availability of their respective IP relay services.

Context

In Accessibility of telecommunications and broadcasting services, Broadcasting and Telecom Regulatory Policy CRTC 2009-430 (RP 2009-430), 21 July 2009, the Commission ordered all local exchange carriers (LECs) that were required to provide Teletypewriter (TTY) Relay to provide 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.

In a series of letters,[1] the Commission and Commission staff addressed requests for extensions to the IP relay launch date set in that regulatory policy, due to technical issues related to the wholesale provision of the service.  The Commission has consistently stated that it is important that high quality relay services be made available to Canadians as quickly as possible. Under the circumstances, the Commission found it appropriate to extend the IP relay service implementation dates on a case-by-case basis, such that LECs were expected to be providing a high quality IP relay service as soon as 21 September 2010 and no later than 30 April 2011. The Commission further stated that it expected all LECs to notify their customers of the availability of their retail IP Relay services, once these were launched.

CAD’s letter

CAD recognized that, due to delays in the launch of the service, IP relay is still in its infancy in Canada but submitted that it was not premature to raise concerns about the quality or functionality of the service.

CAD considered that TSPs had not sufficiently consulted with the Deaf community before the launch of their respective IP relay services. CAD submitted that aspects of the IP relay service are not of sufficient quality to meet user needs. CAD raised specific concerns about (a) the wait times experienced by some IP relay users to make a call, (b) service outages, and (c) the speed of instant messaging platform used to provide the service. CAD also raised concerns that parties were not sufficiently promoting their respective IP relay services.

While CAD raised issues about the provision of IP relay in general, CAD cited specific concerns about quality of service issues with respect to only Rogers  (regarding wait times) and TELUS (regarding service outages). 

Quality of IP relay service

Commission staff notes that it is early in the implementation of the service (i.e. many service providers only began offering the service between March and April 2011). Nevertheless, Commission staff is of the view that it is not premature to expect that IP relay providers are offering a high quality service. The Commission has consistently emphasized the need for IP relay providers to provide their respective customers with access to a high quality service as quickly as possible.

Commission staff further considers that ongoing feedback from users will provide TSPs with the information they need to continue to improve the quality and functionality of the service for their customers. Commission staff expects that as IP relay users raise issues, concerns, and suggestions for service improvement to their IP relay service providers that these TSPs will take these into consideration as they continue to provide the service in order to better serve the needs of their customers with hearing disabilities.

Commission staff notes that the Commission’s approach to addressing complaints related to relay services is to address complaints on a case-by-case basis between the IP relay user(s) and their service provider, in the absence of evidence of systemic issues. 

Given that CAD cited concerns about Rogers and TELUS, commission staff requests that these parties respond to CAD about the issues it raised regarding their respective IP relay service, copying the Commission.  Commission staff also requests that TELUS and Rogers provide the Commission with the following: a) the details of your current IP relay service performance standards; and b) your company’s assessment of its performance in relation to its own performance standards since it began providing the service.

Replies are to be filed and served on interested parties by 15 August 2011. Documents to be filed and served in accordance with this process must be received, not merely sent, by the dates indicated.

Promotion of IP relay service

Regarding CAD’s concerns about the need to promote IP relay service, the Commission has been clear that each IP relay service provider is expected to promote its IP relay service. Given the delays in the implementation of many companies’ IP relay service, Commission staff expects many TSPs to begin promoting the service more significantly in the near future, and will continue to monitor this issue.

Yours sincerely,

ORIGINAL SIGNED BY:

Martine Vallee
Director Social & Consumer Policy, Policy Development and Research

c.c.:  distribution list

Encl: see attachment – letter from CAD – 2 June 2011

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 a.schneider@hay.net; alain.duhaime@sogetel.com; paul.frappier@telmilot.com;
j-fmathieu@telupton.qc.ca; nfrontenac@kw.igs.nettelstep@telstep.net; suivi.roger.roy@sogetel.com; nantel@tellambton.nettelvic@telvic.netscoffey@dryden.cam.baron@brktel.on.cajpatry@telcourcelles.qc.casachuter@tcc.on.caroxboro@ontarioeast.netjdowns@nexicomgroup.net; steve@wtccommunications.ca; regulatory@brucetelecom.comdave.baxter@quadro.net; sgander@kmts.biz; rbanks@mornington.ca; gosfield@gosfieldtel.comnicolet@puc.nettracy.cant@ontera.ca; wagrier@1000island.net; gcordeau@maskatel.qc.ca;  grubb@hurontel.on.ca; regulatoryaffairs@nwtel.ca; pdowns@nexicom.netrob.olenick@tbaytel.com; regulatory@execulink.com; reglementa@telebec.compallard@cooptel.qc.ca; Regulatory.Matters@corp.eastlink.ca; pwightman@wightman.calisa.marogna@cwct.ca

[1] http://www.crtc.gc.ca/eng/archive/2010/lt100511.htm, http://www.crtc.gc.ca/eng/archive/2010/lt100625.htm, http://www.crtc.gc.ca/eng/archive/2010/lt101222.htm, http://www.crtc.gc.ca/eng/archive/2010/lt101203.htm, http://www.crtc.gc.ca/eng/archive/2011/lt110111b.htm, http://www.crtc.gc.ca/eng/archive/2011/lt110405.htm