Philippa Lawson
Senior Counsel
Ms. Diane Rheaume
Canadian Radio-Television and Telecommunications Commission
Ottawa, ON
K1A 0N2
Dear Ms. Rheaume:
Re: Public Notice CRTC 2002-6: Access to Payphones
1.The following submission is made in response to Telecom Public Notice CRTC 2002-6, on behalf of the following groups, collectively referred to herein as “The Consumer Groups”:

  • The Consumers’ Association of Canada, National Anti-Poverty Organization, and Union des Consommateurs;
  • The BC Old Age Pensioners’ Organization, Consumers’ Association of Canada (BC Branch), Council of Senior Citizens’ Organizations of BC, federated anti-poverty groups of BC, Senior Citizens’ Association of BC, West End Seniors’ Network, End Legislated Poverty, BC Coalition for Information Access, and Tenants Rights Action Coalition; and
  • The Consumers Association of Canada (MB. Branch) and the Manitoba Society of Seniors.

2.In PN 2002-6, the Commission invited parties to provide their views, with reasons and supporting information, on access to pay telephone service generally, and on access to payphone service by deaf consumers in particular. Specific issues on which the Commission requested comment include:

  • The extent to which consumers rely on pay telephone service;
  • The availability of pay telephone service to meet consumers’ need;
  • The impact of the removal of pay telephones on consumers;
  • Whether there is a need to establish a regime for public interest pay telephones, and if so, how it should be designed; and
  • Whether there is a need to improve access to pay telephone service by deaf consumers, and if so, how that should be accomplished.

3. In considering these issues, the Consumer Groups found that they did not have sufficient information on which to develop a response. Aside from anecdotal information, it was not clear, for example, to what extent consumers rely on payphones.
4. The Consumer Groups therefore undertook two primary research projects: first, a nation-wide telephone survey of Canadians regarding their use and perceptions of payphone service; and second, a purposive survey targeted at low income Canadians, asking about their use and perceptions of payphone service. The results of each survey are provided in Attachment A and Attachment B, respectively.
5. With respect to the policy questions of whether and how a public interest payphone regime should be established, and whether and how access by deaf consumers should be improved, the Consumer Groups also found that they lacked sufficient information to develop reasoned positions. Much of the information needed for this purpose can only be obtained from the telephone companies, through the interrogatory process. However, some useful information is available from other jurisdictions, in terms of their approaches to the same issues. Attachment C provides an overview of the approaches taken by some other jurisdictions to the issue of public payphone service availability in general. Attachment D provides a brief overview of the approaches taken by some other jurisdictions to the challenge of ensuring access to payphone service by those with hearing impairments, including the profoundly deaf.
6. Based on the evidence that they have been able to gather without the benefit of data from the telephone companies, the Consumer Groups submit that certain conclusions can be reached regarding consumer reliance on payphone service.

Payphones are an important public service

7.The evidence is clear that Canadians consider payphone service to be an important public service.[1] Payphone users feel that the calls they make from payphones are important, while a strong majority, including infrequent users and non-users, say that it is important for others to be able to use payphones to call them.
8.The growth in popularity of wireless phones has by no means rendered payphones obsolete. Indeed, cell phone users (half of those surveyed) are almost as likely as others to use payphone service. However, their frequency of payphone use is much less than that of people without cell phones.
h3. Low income Canadians rely heavily on payphones
9.While a significant proportion of all Canadians (49%) use payphones at least occasionally, a much larger proportion of low-income Canadians (88%) do so. Well over half (59%) of respondents to our low-income survey said that they use payphones at least once a week (vs. 5% of respondents to the EKOS survey), and 22% said that they use payphones daily (vs. 1% of respondents to the EKOS survey).
10.Not surprisingly, people without home phone or wireless service rely heavily on payphones: 93% of the 131 “phoneless” respondents to our survey reported using a payphone at least occasionally, and 82% said that when they need to make a phone call, they go to a payphone. Seventeen percent (17%) said that they use payphones to receive calls.
11. The main reason cited by low income payphone users for their use of payphones is “no other option” (71%). Convenience, while important, is much less likely to be a motivating factor for payphone use by this class of users (46%). A high proportion of low income users report using payphones to call important services (55%) or to make important personal calls (69%).

Payphones are used for a variety of purposes

12.Payphones are used for many different purposes, from social to emergency calling. Convenience and important personal calls are the most common types of calls made (65% and 60%, respectively), but 43% of payphone users say that they have used payphones in the past year to make an emergency or urgent call.
13.Low-income Canadians are more likely than others to use payphones for important personal (69%) and emergency (50%) calls, and less likely than others to use payphones for convenience (58%) calls.
Sizable minorities report problems with payphone availability
14. Forty-four percent (44%) of respondents to the EKOS survey reported sometimes having difficulty finding a payphone when they need one, and 24% (41% in smaller communities or rural areas) said that they had been frustrated by the removal of a payphone that used to be there.
15.One-third (33%) said that they had been frustrated by payphones that are broken, and 44% said that they have sometimes tried to use a payphone and found that it was not working.
16. While availability of payphone service is generally rated as good or excellent, 14% of respondents to the EKOS survey, and 12% of respondents to our low-income survey, rated the availability of payphone service in their area as poor.

The coin payment option is important

17.The vast majority of payphone users (84%) use coins to make payphone calls, and 64% use coins more often than other methods of payment. In contrast, only 23% reported using prepaid cards, and this method of payment was used “most often” by only 6% of respondents.
18. Over one-third (36%) of payphone users have been frustrated by payphones that will not accept coins, and a strong majority (71%) agree that it would be a problem for them if payphones no longer accepted coins.
Lack of incoming call capability is a problem for some
19.Twenty-three percent (23%) of respondents to the EKOS survey said that they used payphones to receive calls from other people, and 21% said that they had been frustrated by payphones that don’t allow incoming calls.

Need for Public Interest Payphones?

20.The evidence suggests that there may be a need for some kind of program to ensure the delivery of payphone service in locations where it is not being provided by market forces alone. Clearly, Canadians, and especially low-income Canadians, rely heavily on payphone service for important calling needs. Yet, it is also clear that the availability of payphones does not always meet consumer needs.
21.In any case, it is unlikely that the social need for payphones will always coincide with profitability of payphone service; some locations will remain unprofitable, yet will serve an important public need. Hence, some kind of regulatory intervention is likely to be necessary in order to ensure that payphones are provided in some locations, where needed.

Design of a Public Interest Payphone regime

22. The Consumer Groups take no position at this time as to the appropriate design for a public interest payphone regime, other than to submit that public interest payphones should:

  • have no less functionality than regular payphones;
  • cost no more than regular payphones; and
  • have the same consumer safeguards as regular payphones.

23. See Attachment C for a description of approaches taken by some other regulators to the provision of public interest payphones.
Access to payphone service by deaf consumers
24. The Consumer Groups agree with the Canadian Association of the Deaf that payphones must be accessible to deaf consumers. Clearly, there is a need to improve access to payphone service by deaf consumers in Canada.
25. Current requirements that all payphones be hearing-aid compatible and provide access to Message Relay Service are insufficient. The former does not accommodate the needs of the many Canadians who are profoundly deaf. The latter is useless to deaf consumers wishing to make a call from a payphone, unless there is a TTY unit attached to the payphone.
26.However, more information on options for the provision of such access is needed before the Consumer Groups can take a position on how the needs of deaf Canadians for access to payphone service should be accommodated.
27.Attachment D provides information on how some jurisdictions are approaching this issue.
All of which is respectfully submitted,
original signed
Philippa Lawson
Co-Counsel for the Consumer Groups
cc:Interested Parties, PN 2002-6
[1] 92% of respondents to the EKOS survey agreed with this statement: “Payphones are an important public service”.