IP Relay
15. In all relay calls, the relay operator is an intermediary between the caller and the intended recipient of the call who transmits messages back and forth. In a TTY relay call, the relay operator transmits messages via TTY-based text conversation with a person with a hearing or speech disability and via voice conversation with a person without such a disability.
16. In an IP Relay call, the relay operator transmits messages via Internet Protocol (IP)-based text conversation with a person with a hearing or speech disability and via voice conversation with a person without such a disability. The person with a hearing or speech disability communicates using text with the relay operator via the Internet and accesses the IP Relay service through the IP Relay provider's Web page or an Instant Messaging application using IP-based text messaging supported on a web-enabled device (mobile wireless phone, smartphone, web-capable telephone, etc.).5
17. From the perspective of a relay service user with a hearing or speech disability, IP Relay is a logical evolution of TTY Relay. Both TTY Relay and IP Relay are text-to-voice relay services; however, IP Relay is not subject to the same technological limitations as TTY Relay. IP Relay enables faster communication between the user with a disability and the relay operator (including calls to 9-1-1). IP Relay enables users to make relay calls using a web-capable device where there is Internet access. IP Relay allows users to see significantly more of the conversation on their computer screens than they can see with a TTY liquid crystal display (LCD) window. IP Relay allows users to print out and save conversations. IP Relay users can initiate multiple calls simultaneously and make conference calls. In light of the above, the Commission considers that the provision of IP Relay would provide significant benefit to TTY Relay users.
18. Based on the record of this proceeding, the Commission finds that it is technically feasible for TSPs to provide IP Relay. The Commission also notes that TTY Relay costs have decreased since the TTY Relay service rates were last adjusted. The record shows that, on average, between the years 2004 and 2008, the ILECs collectively collected 6 $28.5 million per year and collectively spent $11.7 million per year to provide TTY Relay. During that period, the amount collected to provide TTY Relay has exceeded the amount required to provide it by an average of $16.8 million per year. The Commission finds that the recent excess in the rates collected to provide TTY Relay provides the funding to support the introduction and operation of IP Relay as an adjunct to TTY Relay via the same revenue stream.7
19. Accordingly, the Commission finds it appropriate to require the provision of IP Relay.
20. The Commission further finds it appropriate to continue to require the provision of TTY Relay to meet the specific needs of certain Canadians - particularly those who are DeafBlind, those without Internet access and those who access relay services using payphones.
Implementation of IP Relay
21. The Commission directs all LECs, including wireless CLECs, and VoIP providers that are required to provide TTY Relay to provide IP Relay, 24 hours a day, 7 days a week, by 21 July 2010. As with TTY Relay, TSPs may meet the obligation to provide IP Relay by providing the service directly or by outsourcing the provision of the service to a third-party. Further, by 21 July 2010, all references to "message relay service" in the existing relay service requirements set out in previous Commission decisions shall be read to include both TTY Relay and IP Relay.
22. By 21 April 2010 the ILECs are to file revised proposed relay service tariffs. The Commission does not expect the proposed tariffs to include rate increases.
23. The Commission considers that its power under section 24 of the Telecommunications Act to impose conditions on the offering and provision of telecommunications services on Canadian carriers is an appropriate means to impose requirements with respect to IP Relay. The Commission requires Canadian carriers, as a condition of the provision of service, to include in their contracts with resellers, a condition that resellers of local exchange services comply with the same obligations imposed on Canadian carriers.
Video Relay
24. Unlike TTY Relay or IP Relay, Video Relay enables communication with a relay operator using sign language. As such, Video Relay provides significant benefit to those persons with hearing and speech disabilities who communicate via sign language (e.g. American Sign Language (ASL) or Langue des signes québécoise (LSQ)).
25. The Commission considers that the record of this proceeding is insufficient to determine whether TSPs should be required to provide Video Relay. In particular, the record did not establish critical information such as the costs of providing this service, the size of the individual ASL or LSQ Video Relay user markets, or projected use. The record does indicate that the costs of providing a Video Relay service would be high, considering the need for high bandwidth and highly-skilled language interpretation in two sign languages.
26. Therefore, the Commission considers that further investigation into this matter is necessary to acquire accurate information pertaining to cost, user market size and projected use of this service. The Commission intends to assess whether a follow-up proceeding on Video Relay is warranted three years from the date of this Regulatory Policy. The Commission considers that information resulting from the Video Relay initiatives (trials) approved in Telecom Decision 2008-1 is vital to determining whether such a follow-up proceeding is warranted. Therefore, the Commission reiterates its determination that Bell Canada and TELUS Communications Company are to implement the initiatives by the date set out in that Decision (31 December 2011).8 The Commission considers that this timeframe will also allow for actual information pertaining to the use, cost and rates of IP Relay and TTY Relay (information that would be relevant to such a proceeding) to become available.
27. The Commission notes that any TSP may choose to provide Video Relay, on a regional or national basis, subject to Commission approval of a Video Relay tariff.
I cannot agree with you more.
