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Ottawa, 19 January 2012

Mr. Ted Woodhead
Telecom Policy and Regulatory Affairs
TELUS Communications Company
215 Slater Street, 8th Floor
Ottawa, Ontario  K1P 0A6


Dear Mr. Woodhead:

Subject:  Follow-up to the 2011 deferral account report on accessibility initiatives

I am writing in response to a letter from TELUS Communications Company (TELUS) of 15 November 2011 requesting that the Commission approve deferral account funding for its proposal submitted pursuant to Telecom Decision 2006-9 and Telecom Decision 2008-1.

TELUS’ Request for Approval of Deferral Account Funding for its Proposal

TELUS stated that it has allocated $7M from its deferral account since 2008 on initiatives related to accessibility of telecommunications services, and that it recognizes that $1.735M remains to be allocated to specific accessibility initiatives. 

TELUS proposed that the remainder of its deferral account accessibility funds be used for implementing changes to its websites resulting from a review by the CNIB Accessibility Consulting Team as to the conformity of TELUS websites1 to certain accessibility standards.2  TELUS submitted that the changes proposed would address most of the deficiencies that cause TELUS websites to fail these standards.  The proposal also entailed an update of TELUS’ internal processes to ensure consistency with future website developments, and it included high-level details of the proposed changes, a cost study, and the report from CNIB Accessibility Consulting.  These latter items were filed with the Commission in confidence. 

TELUS submitted that this proposal meets the eligibility criteria established in Decision 2006-9 and website requirements of TRP 2009-430, and that the proposed website changes will significantly improve TELUS websites, bringing them further within the requirements of the above-noted standards and rendering them accessible by a wider range of users.  TELUS also submitted that its proposal was developed in consultation with the appropriate disability stakeholder, the CNIB, an organization that represents a well-known resource for Canadians who are blind or partially sighted. 

Background Relevant to TELUS’ Request for Approval of Deferral Account Funding for its Proposal

In Decision 2008-1, the Commission approved the following TELUS initiatives for deferral account funding. 

a. IP Relay

b. Video Relay Service (VRS)

c. Enhanced Directory Service (EDA) free of charge to TELUS special needs customers

d. Improved accessibility of websites 

e. The creation of new programs at TELUS to:

i. Incorporate inclusive design considerations in new service development;

ii. Work with wireless device manufacturers to procure accessible wireless handsets; and

iii. Create a TELUS Accessibility Committee to oversee the development of testing of new TELUS products to ensure delivery and usability of TELUS special needs customers.

f. An unallocated portion for future accessibility initiatives (in TELUS’ case, the portion of the design, development, and implementation that would ensure the accessibility of various IP and presence-based technologies that it would provide).

With respect to unallocated funding, the Commission found in Decision 2008-1 that unallocated funding for future initiatives would be an appropriate use of deferral account funds, and that a public proceeding is the appropriate vehicle to ensure that the future accessibility proposals meet the requirements of persons with disabilities and Decision 2006-9.  Accordingly, the Commission directed the ILECS to submit their future accessibility proposals for Commission approval.  With respect to reporting, the Commission directed the ILECs in Decision 2008-1 to file by 31 March of each year, a report with details regarding the initiatives implemented in the previous year.  The Commission also stated that these funds should be fully utilized within a four-year period ending in 2011.

 TELUS has filed with the Commission reports for 2009 through 2011.  Commission staff has also written to TELUS requesting further detail and clarity in regards to its utilization of deferral funds for each of its initiatives, as well as its plans for remaining deferral account funds. TELUS has responded to these letters.

Commission Staff Comments

Commission staff notes that to date TELUS has not provided any detail pertaining to Initiatives e. and f. (identified above), approved by the Commission in Decision 2008-1.  Given this, it is Commission staff’s position that it would not be appropriate to hold a public proceeding for approval of any proposal for utilization of any unallocated or remaining deferral account funds until TELUS’ reporting is completed, which would include reporting on Initiatives e and f.  


Accordingly, TELUS is to file with the Commission by no later than 27 January 2012 complete reporting pertaining to all of its deferral account accessibility initiatives in accordance with the direction given by the Commission in paragraph 26 of Decision 2008-1.  This information is also to include for each initiative:  

i) the amount originally approved by the Commission;

ii) the amount currently earmarked for completion;

iii) the amount drawn down to date;

iv) amounts remaining and final utilization date;

v) any overall amounts that remain unallocated;

vi) changes resulting from funding reallocations as determined in Decision 2010-679 and Decision 2011-384; and

vii) the status of each initiative and its completion date.

If no progress has been made on any of these initiatives, TELUS is to provide detailed reporting as to the timelines for completion, how these timelines will be maintained, and justification for the delays in light of the Commission’s direction in Decision 2008-1 that these funds should be fully utilized within a four-year period ending in 2011.



Martine Vallee
Director, Social & Consumer Policy
Policy Development & Research


[1] Portions of and

[2] Web Content Accessibility Guidelines (WCAG) 2.0, A & AA level of compliance.

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