ARCHIVED - Letter

Ottawa, 8 February 2011

File Nos.:8678-C12-200615578
8665-C12-200807943
8678-B2-201100594

Mr. David Palmer
Director – Regulatory Affairs
Bell Canada
Floor 19
160 Elgin Street
Ottawa, Ontario K2P 2C4
By email:  bell.regulatory@bell.ca

Re:  Part VII:  Deferral Account Proposal to Improve Accessibility of Mobile Devices and Services

Dear Mr. Palmer:

The Commission is in receipt of an application[1], dated 18 January 2011, made by Bell Canada pursuant to Part VII of the CRTC Telecommunications Rules of Procedure.  In this letter, Commission staff sets out the process associated with the disposition of Bell Canada’s Part VII application and provides associated interrogatories (Attachment).

Bell Canada’s Part VII Application

In its Part VII Application, Bell Canada submitted a proposal (the proposal) for utilization of a portion of its deferral account funds to improve the accessibility of the mobile communications provided by Bell Canada and its affiliate, Bell Mobility.  The proposal consists of two deliveries as given below:

• Delivery A is a plan for Bell Canada to better understand and recommend the appropriate accessibility features of the mobile equipment and applications the Company currently has on hand as well as the introduction of new applications, services, plans and packages to address unmet accessibility needs, based on the input from persons with disabilities.
• Delivery B involves the implementation of the plan developed as a result of Delivery A and is intended to occur over an approximate 12-month period after the completion of Delivery A.

Bell Canada requested Commission approval of the funding required for Delivery A related to project start-up on an expedited basis, and further requested Commission approval in principle of the approach identified for implementation under Delivery B. 

Background

In Telecom Decision CRTC 2008-1, Use of deferral account funds to improve access to telecommunications services for persons with disabilities and to expand broadband services to rural and remote communities,[2] the Commission approved the use of deferral account funds by incumbent local exchange carriers (ILECs), including Bell Canada, for certain initiatives to improve access to telecommunications services for persons with disabilities.  In Broadcasting and Telecom Regulatory Policy CRTC 2009-430, Accessibility of telecommunications and broadcasting service,[3] the Commission requested that wireless service providers, in consultation with persons with disabilities, offer at least one type of wireless mobile handset to serve the needs of people who are blind and/or have moderate-to-severe mobility or cognitive disabilities, noting that it will consider imposing such a requirement in the future if necessary.

Process

• Bell Canada is to file responses to the interrogatories provided in the Attachment to this letter by:  22 Feb 2011, serving a copy on those on the distribution list to this letter.
• Interested parties (other than Bell Canada) may file with the Commission, serving a copy on Bell Canada, comments with regard to the issues raised by Bell Canada in its applications and interrogatory responses by 8 March 2011.
• Bell Canada may file with the Commission, serving a copy on those other parties who have submitted comments, a reply by 15 March 2011.

Considering Bell Canada’s request for approval of funding on an expedited basis and the need for persons with disabilities to take advantage of the initiatives provided for in Bell Canada’s proposal, the Commission expects to issue a decision as soon as feasible after the record closes.

Documents to be filed and served in accordance with the above process must be received, not merely sent, by the dates indicated.

Yours sincerely,

ORIGINAL SIGNED BY:

Mary-Louise Hayward
Manager, Social & Consumer Policy
Policy Development and Research

c.c.:  Martine Vallee, Director Social & Consumer Policy, (819) 997-9254 martine.vallee@crtc.gc.ca

Attachment:

Interrogatories to Bell Canada

Distribution List:

Canadian Association of the Deaf jroots@cad.ca; Ontario College of Art and Design, Treviranus, jtreviranus@faculty.ocad.ca;  ARCH archlib@lao.on.ca;  Council of Canadians with Disabilities, laurie@ccdonline.ca; Independent Living Canada, nationaldirector@ilc-vac.ca; Canadian National Institute for the Blind (CNIB), cathy.moore@cnib.ca; Canadian Council of the Blind, mpotvin@ccbnational.net; Ottawa Deaf Centre, newfiedjh@yahoo.com; Ontario Association of the Deaf, dean@deafontario.ca; The Canadian Hearing Society, ckenopic@chs.ca; Canadian Association for Community Living, mbach@cacl.ca; Centre québécois de la déficience auditive, cqda@videotron.ca; Public Interest Law Centre, mybow@legalaid.mb.ca; Disability and Information Technologies (Dis-IT), ine@ccdonline.ca; d_stienstra@umanitoba.ca; Alliance for Equality of Blind Canadians/L'Alliance pour l'égalité des aveugles canadiens, mworkman@blindcanadians.ca; Farah.mughal@rci.rogers.com; Neil Squire Society, garyb@neilsquire.ca;  Chris Stark, stark.chris@rogers.com; Clayton Zekelman, clayton@MNSi.Net

ATTACHMENT (Interrogatories to Bell Canada):

1000.  General:  Deliveries A and B

1001.  Provide the following information:

A. The overarching accessibility objectives that Bell Canada (the Company) plans to achieve with the proposal in this application;

B. Expected overall outcomes and benefits with illustrating examples;

C. Evaluation criteria/process that the Company intends to establish in order to assess how the outcomes will address the needs identified by the stakeholders; and

D. How the principles of universal/inclusive design and accessibility will be applied to the expected outcomes.

1002. Explain the relationship, if any, between the proposal in this application and the Company’s other accessibility-related deferral account projects (e.g., website accessibility, Video Relay Service (VRS), etc.) that were approved in Telecom Decision CRTC 2008-1, Use of deferral account funds to improve access to telecommunications services for persons with disabilities and to expand broadband services to rural and remote communities (the Deferral Account Decision).

1003.  At paragraph 6 of its proposal, the Company states that it is focusing on addressing accessibility issues related to specific services identified by stakeholders, such as website accessibility, video relay service and inclusive design with respect to IPTV.   Clarify whether this proposal provides for accessibility initiatives related to IPTV. 

1004.  Provide an overall estimate of cost for the work described in the Company’s application, broken down for all of the key components including:  the five key initiatives, the consultant, and the advisory committee.

1005.  To what extent, if any, will the improvements in accessibility expected from this application extend beyond Bell Canada’s wireless service?

1006.  This 2-stage process proposed by the Company appears to not meet the Commission’s conclusion in the Deferral Account decision that accessibility funds should be fully utilized by 2011.  How could the proposal in this application be modified to comply with this conclusion?

2000.  Content of the Proposal regarding Delivery A

2001.  Paragraph 18 of the Company’s application states that the plan developed through Delivery A will:

“…focus on five key initiatives:  a) web tools to assist Bell Mobility personnel to recommend appropriate solutions and allow customers to make their own decisions about accessibility options; b) improved marketing of accessible technology and improved distribution through retail channels, c) improved lifecycle management, d) accessibility procurement protocols for mobile products and services; and e) assessment of unmet accessibility needs related to mobile products services and solutions.  The Company has reviewed these initiatives with stakeholders as part of its consultations and has received strong support for them. ”

Provide the following information for each of the five key initiatives given above:

A. A description of the area of the initiative including:  why it was selected, the purpose that it serves, the customers and needs that it is intended to serve, how it will work, and expected outcomes with illustrating examples;

B. Whether the initiative is premised on existing technology, service, or capability;

C. How the initiative is interrelated with the other deferral account initiatives;

D. The manner in which the initiative will improve accessibility;

E. The nature of the consultation process around the initiative with key stakeholder groups, and how these consultations informed the Company’s choices concerning the initiative;

F. How the Company envisions the integration of universal/inclusive design principles;

G. The evaluation criteria that the Company will use to measure compliance with the needs identified by the stakeholders;

H. Estimated cost;

I. The number of anticipated customers and projected date of offer;

J. Sustainability considerations, concerns or requirements, once deferral funds are depleted.

2002.  Paragraph 4 of the Company’s application states:

“Each deliverable under this proposal goes beyond the requirements for accessible mobile services set out at paragraph 44 of Broadcasting and Telecom Regulatory Policy CRTC 2009-430, Accessibility of telecommunications and broadcasting services (Policy 2009 430) and goes beyond what is currently available from Canadian Wireless Service Providers (WSPs).  The Company submits that deferral account funding is appropriate for the implementation of this proposal and the proposal will significantly advance the accessibility of mobile products and services to people with disabilities.”

Explain:

A. How each deliverable goes beyond the requirements for accessible mobile services set out in paragraph 44 of Policy 2009-430[4]; and

B. How implementation of this proposal will significantly advance the accessibility of mobile products and services to people with disabilities.

2003.  Paragraph 9 of the Company’s application states: 

“Despite the discussions that have taken place over the last several years, there is a lack of detail on exactly what unmet needs exist, which of those needs can be addressed by WSPs and whether some of those needs can be addressed by handsets and applications already in the Company's inventory.” 

Explain the extent to which the investigations in this proposal in this application will:

A. Study and address the “lack of detail in unmet or underserved needs” in the accessibility of the Company’s products and services that are the subject of this proposal, in particular wireless products and services; and

B. Consider solutions for these unmet needs that may exist outside of the company’s existing inventories or capabilities.

3000.  Role of the Consultant/Role of the Advisory Committee

3001.  Paragraph 15 of the Company’s application states that the Company intends to hire a consulting firm skilled in accessibility and inclusive design to work with Bell Mobility personnel to develop Delivery A.  Provide the following information:

A. Specify the role of the consultant and the nature of the work that will be commissioned

B. Explain how the Company plans to communicate input (e.g., reports, etc.) received from the consulting firm to key stakeholders, how the Company will provide for comment by key stakeholders, and how the Company will apply such information to the initiatives that it has described in its application; and

C. Estimated cost

3002.  Paragraph 17 of the Company’s application states that the “Company does not believe that the plan envisioned in Delivery A can be successful without the participation and support of the disability stakeholders”.  Paragraph 39 states that the “Company proposes to create an Advisory Committee to provide input and oversight for all parts of the proposal”.  Provide the following additional details:

A. What the mandate of the Advisory Committee will be;

B. What the composition of the Advisory Committee will be, and to the extent to which it will provide for representation of persons with various types of disabilities, in particular:  persons who are blind or have vision disabilities; persons who are deaf or have hearing disabilities; persons who are deaf-blind; persons who have mobility disabilities; and persons who have cognitive disabilities;

C. How the Advisory Committee will be structured.  How it will work.  How it will inform the decisions made by the Company throughout the various stages of its proposal;

D. The estimated cost, including a breakdown of costs covered (for example, per diem, travel, etc.); and

E. How the Committee will be sustained once the project is complete.

4000.  Sustainability and Delivery

4001.  Sustainability.  Provide details on:

A. How the initiatives in the Company’s proposal (both Deliveries A and B) will be sustained once deferral account funds are depleted; and

B. How these initiatives will be integrated with the Company’s business plans and processes.

4002.  Delivery.  Provide a detailed explanation of the expected outcome of the Company’s complete proposal in this application (both Deliveries A and B), and the concrete benefits that it will deliver in improving the “Accessibility of Mobile Devices and Services”.

kier@cailc.ca  was not delivered and was replaced by: liaison@ilc-vac.ca

[1] http://www.crtc.gc.ca/PartVII/eng/2011/8678/b2_201100594.htm

[2] http://www.crtc.gc.ca/eng/archive/2008/dt2008-1.htm

[3] http://www.crtc.gc.ca/eng/archive/2009/2009-430.htm

[4] Accordingly, the Commission requests that, by 21 October 2009, all WSPs offer and maintain in their inventories at least one type of wireless mobile handset that will provide access to wireless service by persons who are blind and/or have moderate-to-severe mobility or cognitive disabilities

Date modified:

2011-02-08