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File No.: 8665-C12-201303536
By e-mail
To: Distribution List
Re: Issues related to the feasibility of establishing a video relay service Telecom Notice of Consultation CRTC 2013-155
The Commission has received your intervention to Telecom Notice of Consultation CRTC 2013-155. Requests for information are set out below. Responses to the following clarification questions are to be filed by 12 July 2013. Please note that question one applies only to the local exchange carriers (LECs) included in the distribution list and the remaining questions apply to all parties included on this distribution list.
The following questions are to be answered by Local Exchange Carriers (LECs) on the distribution list:
1. In the event the Commission determined that video relay service (VRS) should be introduced and funded through a centralized fund:
a) Should the existing National Contribution Fund (NCF) be expanded to collect and disburse the VRS funding or should a new centralized fund with separate reporting be established for this purpose? Provide details, including your definition of contribution-eligible revenue to be used and full rationale.
b) Currently, only telecommunication service providers (TSPs), or groups of related TSPs, with $10 million or more in Canadian telecommunications service revenue are required contributors to the existing NCF.
Should a telecommunications service revenue cut-off be established for VRS funding? What should this revenue cut-off be, and provide your rationale.
c) Identify the procedural changes, if any, which would be required to permit the collection of VRS funding under the existing NCF. The current NCF procedures can be found in Revised Procedures for the Operation of the National Contribution Fund, effective 1 September 2011, Telecom Decision CRTC 2011-529, 25 August 2011.
d) With respect to the existing message relay service (MRS) rates per Network Access Service (NAS), comment on the Sorenson proposal that the existing MRS rates be maintained with any surplus collected flowing into the VRS fund.
The following questions are to be answered by all parties on the distribution list:
2. In the event the Commission determined that the existing MRS obligation be extended to include VRS, and given that the Federal Communications Commission (FCC) has reported that VRS providers’ weighted average actual per-minute costs were $3.1900 for 2011, and $3.4313 for 2012 . :
a) Assume that VRS is classified as a public good service, comment on setting a VRS tariffed-rate based on the above noted costs, reported by the FCC, plus a mark-up of 15 percent. In your response, comment on (i) whether this tariffed rate would be sufficient to cover costs in the LEC’s serving territory where VRS is provided directly by the LEC and (ii) whether this tariffed rate would incent the provision of wholesale VRS by a third-party provider. Provide detailed rationale for your response.
b) Multiple interveners stated that in the instance VRS is mandated, they would support the development of a model like the one proposed by Mission Consulting in their VRS Feasibility Study submitted by Bell Canada . The cost of this model was based on the assumption of a $4.30 per-minute reimbursement rate for potential Canadian VRS providers. This rate is higher than the FCC reported weighted average actual per-minute costs plus 15 percent. Comment on (i) whether a tariffed-VRS rate of $4.30 would be sufficient to cover costs in the LEC’s serving territory where VRS is provided directly by the LEC and (ii) whether this tariffed rate would incent the provision of wholesale VRS by a third-party provider. Provide your rationale.
For both parts (a) and (b) indicate whether this tariffed rate would allow the company to offer VRS either directly or through a third-party (1) 8 hours a day, 7 days a week (2) 12 hours a day, 7 days a week and (3) 24 hours a day, 7 days a week. In your response, state the applicable service standards.
3. Comment on the provision of VRS based on a fixed number of funded interpreter (VRS operator) positions as discussed in UQAM and SIVET’s joint supporting intervention (intervention number 2865) . In your response, describe the manner in which the number of fixed VRS operator positions should be determined and the criteria used to arrive at this determination. Describe how the costs could be shared, under both a centralized fund and a tariffed rate.
Please contact Kay Saicheua (kay.saicheua@crtc.gc.ca) at (819) 934-1358 should you have any questions in regard to this letter.
Yours sincerely,
ORIGINAL SIGNED BY/
Nanao Kachi
Director, Social & Consumer Policy
Distribution List
bell.regulatory@bell.ca; regulatory@bell.aliant.ca; regulatory.matters@corp.eastlink.ca;
telecom.regulatory@cogeco.com; iworkstation@mts.allstream.com; regulatoryaffairs@nwtel.ca; dennis.beland@quebecor.com; rwi_gr@rci.rogers.com; document.control@sasktel.com; regulatory@sjrb.ca; isabelle.morneau@telus.com; regulatory.affairs@telus.com
IVéS, olivia.bonfils@ives-inc.ca ; didier.chabanol@ives.fr
nWise, thor.nielsen@nwise.se
Sorenson Communications and Sorenson Communications of Canada, ULC, greg.kane@dentons.com
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