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Ottawa, 15 May 2012

File No.  8678-B2-201100594

Mr. Bill Abbott
Senior Counsel & Bell Privacy Ombudsman
Bell Canada
Floor 19
160 Elgin Street
Ottawa, Ontario K2P 2C4

By email:

Re: Request to Bell Canada to disclose certain information designated as confidential in its “Accessibility Proposal for Mobile Telecommunications Devices and Services” (the Mobility Accessibility Initiative) 1  

Dear Mr. Abbott:

With this letter, Commission staff is requesting Bell Canada (Bell) to disclose certain information for which it has claimed confidentiality in the above-referenced application, filed with the Commission on 11 April 2012.  The information in question is set out in the Attachment to this letter. 

At the time that Bell filed this application, it designated the information in the Attachment as confidential and filed an abridged version with the Commission in accordance with Sections 31(1) and (2) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules).  Bell provided at paragraph 10 of its application, the following reason for its claim of confidentiality.

“Certain information contained in this proposal and the Attachments is filed in confidence with the Commission pursuant to section 39 of the Telecommunications Act and the directions provided by the Commission in the Appendix to Broadcasting and Telecom Information Bulletin CRTC 2010-961, Disclosure Guidelines.  In particular, the information which the Companies have provided in confidence is of a type which the Commission has indicated in that Appendix should be treated as confidential.  Release of this information would provide potential competitors with invaluable competitively-sensitive information that would not otherwise be available to them, and which would enable them to develop more effective business strategies. Release of such information could prejudice the Companies' competitive position resulting in material financial loss and cause specific direct harm to the Companies.”

Commission staff notes that in its claim for confidentiality, Bell did not explain how this information is of a type listed in the appendix to Bulletin 2010-961 nor did Bell provide detailed rationale to explain why disclosure of this information is not in the public interest.  .  Commission staff notes that at paragraph 6 of Bulletin 2010-961, the Commission states:

“Generic statements such as “the release of this information to competitors would result in specific, direct harm to the company” are not sufficient.  Parties must provide sufficient reasons to allow meaningful analysis by the Commission or another party who may wish to request disclosure of the information.”

Bell Canada is to provide its reply no later than 10 days after receipt of this letter.



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


Attch. (1)

Paragraph No.



Estimated totals for this proposal, Delivery A, and Delivery B


Amount spent to facilitate three Advisory Committee meetings, hire an accessibility consultant to perform audits of Bell practices and make recommendations, and hire a project manager to oversee the activities.


Estimated drawdown for sourcing and packaging of mobile devices and applications to address accessibility needs


Estimated drawdown for Education & awareness of Bell accessibility initiatives


Estimated drawdown for creation of web tools to support accessibility handset, applications, and accessory selection


Estimated drawdown for improvements to company operations, and client support tools


Estimated cost to co-develop a bilingual screen-reader


Estimated cost to procure, test, and establish distribution to Bell clients for Mobile Accessibility


Estimated cost to procure and establish distribution to Bell clients for Tecla Access


Estimated cost for use of direct marketing channel assets


Estimated cost for use of Mass Marketing channel assets


Estimated cost for use development and implementation of product tutorials

[1] The Mobility Accessibility Initiative consists of two deliveries:  Delivery A provides for a plan; Delivery B provides for the implementation of that plan.  In a letter dated 29 April 2011, the Commission approved Delivery A and directed Bell to provide on 3 October 2011 the detailed information listed below when it files with the Commission the results of Delivery A and its request for approval of Delivery B. 

In a letter dated 23 December 2011, the Commission extended the delivery date for Delivery B of to 2 April 2012 and, in addition to the above deliverables, directed Bell to provide regular progress reports and minutes of meetings held with the Disability Advisory Committee as approved by these stakeholders.

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