Executive Summary of Argument
Wednesday, August 11, 2004
Public Notice CRTC 2002-6: Access to Payphones
Argument of the Consumer Groups
EXECUTIVE SUMMARY
Public Interest Payphones
- Payphone service is considered an important public service by almost everyone, and is relied upon by a wide spectrum of consumers, not just those without home phone service or wireless service.
- A significant minority of users is dissatisfied with the availability of payphones, and report frustration as a result of payphone removal or difficulty finding a payphone when they need one. Meanwhile, payphone availability is steadily declining, at a rate of app.3% per year.
- It is therefore appropriate for the regulator to take action to ensure that payphone service continues to be provided where needed. However, it is not clear whether a subsidy is needed to accomplish this.
- It is preferable, everything else equal, for location providers and/or payphone service providers to cover the costs of non-compensatory payphones (as is currently the case) rather than to establish a new subsidy regime paid for by subscribers or users.
- The Consumer Groups therefore propose the following approach, applicable to all pay telephone service providers (PSTPs) unless otherwise stated:
- a three-year period during which payphone needs (including consumer complaints) are more closely monitored, and during which PTSPs are under regulatory obligations to notify affected communities and interested parties, and to seek location providers (see argument for detailed proposal); and
- a review after three years, to determine whether this approach is adequate, and if not, to establish a mandatory regime for public interest payphones.
- All payphones should have the same basic functionality, consumer safeguards, and price.
- Directory assistance should continue to be free from all payphones.
- Every payphone location should include a coin-operated payphone, except where specifically approved otherwise by the CRTC.
- The issue of calling card interoperability should be addressed, possibly via a follow-up to this proceeding. This issue should be given higher priority depending on the extent to which the Commission permits the provision of payphones without a coin payment option.
- Incoming call capacity should be offered at the discretion of the location provider (as is apparently the case now). When incoming call capacity is removed from a payphone, notice should be posted on the payphone explaining why it has been removed.
Accommodation of Deaf Consumers
- Deaf consumers have a right to access public payphones.
- This right should be accommodated in a manner that does not cause undue hardship to others. In particular, the accommodation of deaf consumers should not have the effect of reducing general payphone availability, accessibility, or affordability, or of reducing basic service affordability;
- The accommodation of deaf consumers should therefore not be funded via an increase in the price of payphone service or general phone service, such that the availability or affordability of either service is compromised;
- A joint CRTC/Canadian Human Rights Tribunal proceeding should be initiated to develop comprehensive rules for the accommodation of deaf consumers in respect of public payphone service;
- A pilot project should be initiated to assess the costs and benefits of different approaches to accommodation of deaf consumers;
- All new payphone banks of four or more payphones (including those that have simply been expanded) should include a TTY unit, unless there is another TTY-equipped payphone within 70 metres;
- All TTY-equipped payphones be well-signed; and
- All new payphones be equipped with volume control buttons and an acoustic hearing aid coupler in the handset to accommodate hearing-impaired consumers.
END OF DOCUMENT