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File No.: 8665-C12-201303536
By e-mail
Sorenson Communications and Sorenson Communications of Canada, ULC
c/o Gregory Kane, Q.C
Dentons Canada LLP
99 Bank Street, Suite 1420
Ottawa, ON K1P 1H4
Greg.kane@dentons.com
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. Please find a request for information below. Responses to the following clarification questions are to be filed with the Commission by 12 July 2013.
1) In paragraph 56, Sorenson states that "data generated by the Telus trial are remarkably consistent with the usage data derived by Sorenson…”. Sorenson later submits its costing estimate for a Canadian VRS (Appendix 1) and this projection utilizes an average of 60 minutes of VRS/month/installation whereas the Telus trial reports 108 minutes of VRS use per month per installation. Please clarify which results this comment in paragraph 56 refers to. Please indicate which monthly level of usage per installation is a more accurate projection for Canada. Provide your rationale.
2) In Paragraph 57, Sorenson provides cost estimates for years 1-5 and states that the annual cost "will then decrease [from year 5] on an annual basis on the assumption that the fixed per minute rate for calling will decline over time". Given that 80 percent of direct VRS costs are interpreter-associated costs which are less likely to decline over time, please justify this statement.
3) In Paragraph 111, Sorenson states that the "additional cost associated with providing 24/7 VRS is negligible as there is little traffic during the off hours". Please confirm that Sorenson is referring to the cost billed to the VRS fund, assuming a per-minute reimbursement rate is adopted, and not referring to the cost borne by the VRS provider in offering this service during the off hours.
4) During the Sorenson/Telus 18-month trial, VRS was offered 24 hours a day, seven days a week during the months of February to July 2011. The hours were later reduced to 5am to midnight from August 2011 to January 2012. Telus’ final report states that “the Company had introduced this reduced VRS availability because very low VRS call volume had been experienced during that 5-hour period [i.e. midnight to 5am]. This low call volume did not justify the costs to maintain service availability for those hours” and further states that “Telus decided to limit the hours of operation to maintain a good relationship with its vendor…” Please provide the average profitability rate for the 12am to 5am session experienced by Sorenson. Alternatively, describe the impact of this reduced schedule on overall profitability and express this on a percentage basis.
5) Refer to Appendix “1” of Sorenson’s submission.
a. The Assumption Summary states that the starting rate of $5.94 submitted is consistent with what the FCC is currently considering as the tier 1 rate (the rate applicable for providers reporting 50,000 conversation minutes or less per month). Considering VRS is offered 24 hours a day, seven days a week in the United States, and the cost savings experienced by VRS providers in not offering VRS during off times, please provide a revised per-minute rate based on the reduced schedule of (i) 5am-12am and (ii) 6am-10pm seven days a week as per the sessions trialed during the Telus 18-month trial. Provide detailed calculations and list all assumptions.
b. Please verify your Total Annual Minute and Total Annual Funding figures as they are not aligned with the assumptions listed in the “Assumption Summary”. If applicable, resubmit an adjusted Appendix 1, including detailed calculations and assumptions used to estimate the Total Annual Minutes for each of the years.
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
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