ARCHIVED - Letter
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Ottawa, 26 October 2011
File No.: 8678-B2-201100594
Mr. Bill Abbott
Senior Counsel – Regulatory Law
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario, K2P 2C4
By email: bell.regulatory@bell.ca
Re: Deferral Account Proposal to Improve the Accessibility of Mobile Devices and Services – Request for Extension
Dear Mr. Abbott:
I am writing in response to your letter dated 3 October 2011. In that letter, Bell Canada (the Company) requested a six-month extension to 2 April 2012 for the provision of Delivery A of its two-part initiative for improving accessibility of the Company’s mobile devices and services (the mobility accessibility initiative).
Background
On 11 January 2011, the Company filed an application with the Commission, pursuant to Telecom Decisions CRTC 2006-9 and 2008-1,[1] requesting approval of deferral account funding for the mobility accessibility initiative. This initiative has two deliveries. Delivery A provides for a plan and Delivery B provides for the implementation of that plan. The public record, which closed on 15 March 2011, is available on the Commission’s website at: http://www.crtc.gc.ca/PartVII/eng/2011/8678/b2_201100594.htm.
The Commission approved in a letter dated 29 April 2011 the use of deferral account funds for Delivery A, and directed the Company to provide in five months’ time (3 October 2011) a detailed economic study along with the results of Delivery A when it files with the Commission its request for approval of Delivery B.[2] Delivery B, according to the Company’s application is intended to occur over an approximate 12-month period after the completion of Delivery A (mid October 2012).
The Company’s request for extension
The Company requested a six-month extension for two reasons. First, the preliminary work with the selected accessibility consultant in defining the detailed scope and objectives of Delivery A has taken considerably longer than anticipated and, second, the remainder of the work involved in finalizing Delivery A will take longer than anticipated considering its breadth. The Company also submitted that this advance work is necessary to ensure that the process of developing the Delivery A plan is effective and collaborative and that the resulting plan is both practical and of high quality.
Conclusions
In Decision CRTC 2008-1 dated 17 January 2008, the Commission set out its timeframe for utilization of remaining deferral account accessibility funds and considered that these funds should be fully utilized within a four-year period ending in 2011.[3] I note that the Company’s requested six-month extension would push the completion of Delivery A out to 2 April 2012. This date effectively places the completion of the entire mobility accessibility initiative outside of the Commission’s above-stated fund utilization period.
I note also that the Company’s letter neither fully explains the nature of the delay for Delivery A, nor does it sufficiently justify the need for the requested six-month extension. Further, the letter does not state the anticipated impact that a six-month extension would have on the completion of Delivery B, nor does it state how the Company will manage the initiative to maintain the completion dates as given in the Company’s original application. Lastly, I note the late nature of the Company’s request for an extension, which was made on the same day as the Commission’s deadline for completion of Delivery A.
Given these factors and considering the amount of time that has elapsed since the Commission issued Decision CRTC 2008-1, the timely fruition of the benefits promised by mobility accessibility initiative to persons with disabilities appears to be at risk. Moreover, the deferral account funds earmarked for this initiative also appear to remain underutilized. As set out in my letter of 3 February 2011, the Commission may consider directing allocation of these funds to promote the accessibility of telecom services.
In light of the foregoing, the Company is to file Delivery A no later than 29 December 2011, along with its filing for approval of a detailed report regarding Delivery B as set out in the Commission’s letter of 29 April 2011. Also when filing this information with the Commission, the Company is to provide detailed reporting as to how it intends to manage the key timeframes for Delivery B in order to maintain the deliverable dates as specified in the Company’s application for this initiative.
Sincerely,
ORIGINAL SIGNED BY /
Martine Vallee
Director, Social & Consumer Policy
Policy Development and Research
cc. mary-louise.hayward@crtc.gc.ca; Nanao.Kachi@crtc.gc.ca; catherine.lemieux@crtc.gc.ca
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; petricoi@lao.on.ca; Council of Canadians with Disabilities, laurie@ccdonline.ca; Council of Canadians with Disabilities, ccd@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; Ms. Denise Sayer, Susan.Brown@paliareroland.com ; Mr. David Lepofsky dlepofsky@sympatico.ca
[1] Telecom Decision CRTC 2006-9, Disposition of funds in the deferral accounts.. 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 also directed the Company to provide, when it files with the Commission its request for approval of Delivery B, formal detailed reporting in the following areas of unmet accessibility needs: universal/inclusive design; evaluation criteria/process; lifecycle support/management; and sustainability.
[3] Paragraph 25.
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