ARCHIVED -  Letter

1. At paragraph 44 of Broadcasting and Telecom Regulatory Policy CRTC 2009-430, Accessibility of telecommunications and broadcasting services, the Commission requested 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.
   1. Explain precisely which initiative set out in your application will meet the direction above set out by the Commission for:
      1. persons who are blind
      2. persons who have moderate-to-severe mobility disabilities
      3. persons who have moderate-to-severe cognitive disabilities
2. At paragraph 8, Bell describes how funding will be allocated across the following four initiatives.  At paragraph 4, Bell states that its Mobility Accessibility proposal is estimated to draw down $6.5M in deferral account funding over a period of three years.

Initiative	Estimated Drawdown
Sourcing and packaging of mobile devices and applications to address accessibility needs	2.0 M$
co-develop a bilingual screen-reader	1,5  M$
procure, test, and establish distribution to Bell clients for Mobile Accessibility	0,4 M$
procure and establish distribution to Bell clients for Tecla Access	0,1 M$
Education & awareness of Bell accessibility initiatives	2,5 M$
direct marketing channel assets	1,2  M$
mass marketing channel assets	0,5  M$
development and implementation of product tutorials	0,8  M$
Creation of web tools to support accessibility handset, applications, and accessory selection	0,7 M$
web based handset selector	0,4 M$
upgrading web content to WCAG 2.0 Level AA compliance	0,3 M$
Improvements to company operations, and client support tools	1,3 M$
client care training.	0,4 M$
Mobile Remote Device Management (RDM)	0,4 M$
accessibility lifecycle management	0,5 M$
Total	6,5 M$

1. With respect to the cost estimates set out in paragraphs 38, 48, 62, and 84 of the Accessibility Proposal for Mobile Telecommunications Devices and Services (the Proposal):
   1. For each deliverable listed in the paragraphs noted above (e.g. “co-develop a bilingual screen reader application…”), provide a further breakdown of costs into major cost components, with supporting methodology and assumptions for each major cost estimate.  Also explain whether each cost item is driven by the company’s labour rates, third party rates, hardware costs, software costs, or other costs (specify), with supporting rationale.
   2. Indicate the study period years in which the proposed costs provided in response to (i.)  will be incurred, with supporting rationale.
2. Refer to paragraph 6 of the Proposal and the Companies’ statement that: “The Companies note that its cost study, included as Attachment 1, which outlines a projected drawdown of $6.9M is a preliminary estimate only, and will be adjusted as this project is deployed.”
   1. For each of the deliverables provided in paragraphs 38, 48, 62, and 84 of the Proposal:
      1. Identify which costs the company considers are most likely to change and which are not. 
      2. For those deliverables whose costs are considered to be the most likely to change, estimate the potential magnitude of change (e.g. 10%, 20%, 50%) and state whether the change is estimated to be an increase or decrease in cost, with supporting rationale.
   2. Assume that the company’s total current cost estimates are subject to future upward revisions to complete the deliverables in each category as currently described.  Discuss whether the company would modify the Proposal in order to complete it using the amount of funds requested from the deferral account in this application.
      1. If no, discuss how the company plans to fund the increased costs.
      2. If yes, describe fully how the Proposal would be modified if the total cost increased by each of 10%, 20%, 30%.  For each cost increase scenario, include, with reasons, the company’s priority ranking of all deliverables as provided in Paragraphs 38, 48, 62, and 84 of the Proposal, highlighting which deliverables the company considers most valuable in providing sustainable benefits to groups requiring improved accessibility in mobile communications.
   3. Provide comment, with supporting rationale, on the appropriateness of annual reporting on progress towards project completion and the expenditure of any deferral account funds received in relation to Accessibility Proposal for Mobile Telecommunications Devices and Services spending.
3. See the below chart that illustrates percentage allocation as described in the Proposal.  Confirm that the Advisory Committee agrees that this initiative allocation of $6.9M for Bell’s proposed Mobility Accessibility Initiative is appropriate.

   

4. Should actual costs for the activities in the above table be greater than those estimated: List in sequence Bell’s priorities for delivering the above-listed initiatives.
5. Specify the project management methodology that Bell will use to manage the Mobility Accessibility Initiative.
6. Provide a comprehensive project plan for the above-listed initiatives that shows start and finish dates, critical paths, interdependencies that would tie any of these initiatives to a common delivery date.  Include in this plan:
   1. Bell’s risk management strategy for assuring that all of the initiatives in Bell’s application and their dependencies are delivered in accordance with the project plan and its timelines.
   2. A detailed description of the status-reporting documents that Bell plans to deliver to the Commission to report on the status of the Mobility Accessibility Initiative (for example, will they include planned/actual completion status; issues and risks; funding status; project performance; etc.).
   3. The dates that status-reporting documents will be delivered to the Commission.
   4. The dates for planned meetings with the Advisory Committee and the planned dates that the minutes for these meetings will be delivered to the Commission.
7. Provide the five reports referenced in paragraph 2 of Bell’s letter of 2012-01-16¹ where Bell states that these would be available in the second half of March 2012.

2.0  Advisory Committee/Consultant

At paragraph 18, Bell states that “the Companies will continue to work with stakeholders to ensure ongoing input throughout the implementation process.  The Companies are committed to the idea that real improvements in accessibility are possible only with the active participation of the groups that represent and understand the needs of persons with disabilities.”

Refer to Bell Canada(CRTC)8Feb11-1004 D2006-9,² Bell’s interrogatory response for its submission of 18 January 2011.  Bell provided the following information concerning the roles of the Consultant and the Advisory Committee:

• Consultant – The Company intends to hire a consulting firm skilled in accessibility and inclusive design to work with Bell Canada personnel to develop Delivery A and assist with the execution of Delivery B.
• Advisory Committee – The Company proposes to create an Advisory Committee to provide input and oversight for all parts of the proposal.  The Advisory Committee will be made up of key representatives from accessibility groups and stakeholders within the Company.  Advisory session meetings will be scheduled throughout Delivery A and Delivery B. 

1. Confirm that Bell plans to continue to utilize both a Consultant and the Advisory Committee throughout the implementation process of its Mobility Accessibility Initiative (i.e., throughout the implementation of Delivery B).
2. If yes,
   1. Confirm that these resources are in place.  Provide the names of the Consultant and each member of the Advisory Committee.
   2. Identify any changes with substantiating rationale that Bell plans to make in regard to the roles and/or functioning of these two resources.  These would include, for example mandate, structure, number of meetings, etc.
   3. Provide the process that Bell will use to implement the input from these two resources.
3. If no, explain with substantiating detail why Bell has decided to change this approach.  Include in your answer the approach that Bell plans to take to address the need for accessibility expertise in light of Bell’s recognition “...that there are gaps in its ability to assess the needs of persons with disabilities and to develop appropriate methods for recommending the appropriate solutions.”³
4. Provide a breakdown of costs related to the Consultant and Advisory Committee as these were not provided in Bell’s application.

3.0  Assessment of Unmet Needs

A. Paragraph 19 states that assessments were made of unmet usability needs of current and/or potential wireless customers with disabilities that included expert evaluation of Bell’s website, call centre operations and retail stores, amongst other things.  Provide in its entirety reporting provided to Bell by the IDRC in relation to IDRC’s accessibility assessment of the areas listed above.  Reporting would include, but not be limited to, information and details pertaining to the accessibility of these areas, methodologies, actual assessments, results and findings, analyses, gap analyses, recommendations, internal solutions, etc.

B. Paragraph 22 references Attachment 6 as an “exhaustive list” that represents the product and service-related gaps at Bell.  Attachment 6 provided by Bell in its application to the Commission is entitled Last Mile Improvements for Apple iPhone Series.

1. Confirm whether Attachment 6 as provided is the “exhaustive list” referenced in paragraph 22.
2. If not, provide the referenced list.

4.0  Screen-reading Feature Phone

At paragraph 31, Bell states that it commits to working with at least one major handset manufacture to add screen-reader functionality to a feature phone with a tactile 3-key by 4-key keypad.  Bell states that this would include negotiating with the supplier to introduce a phone with screen-reader functionality that has been used in feature phones in other markets (i.e., United States).  This will be developed and incorporated into feature phone handsets purchased from the supplier on an ongoing basis, making the initiative sustainable in the longer term.  The intent is for the screen reader to be present on a feature phone that also has large, differentiated buttons, system-wide control of text font, size and colour, speakerphone functionality, Teletypewriter (TTY) compatibility, a simple user interface, and short cuts to access commonly used features.  Once complete, this initiative will meet the needs of customers with mild to severe visual impairments, mild to moderate physical impairments, certain cognitive impairments, or a combination of disabilities.

1. Confirm that the proposed feature phone with screen-reader functionality will meet the accessibility needs of persons who are blind (given your statement that “Once complete, this initiative will meet the needs of customers with mild to severe visual impairments...”)
2. Explain in detail how the screen reader features of this proposed feature phone will meet the accessibility needs of Bell’s customers with the above-listed disabilities.  Include the following information in your response:
   1. The extent to which the screen-reader will provide accessible access to the functions of the proposed phones, including:  voice commands; read-out of all indicators (time, battery, etc); read-out of screen information (contact lists, all menu/sub-menu levels, etc.); read-out of the functions of key user buttons; read-out of caller information (caller ID, missed call information, etc.); incoming and outgoing text messages; etc.  In your answer, please provide a comparison of any differences in the screen-reader capabilities between the proposed feature phone and smartphones (such as the iPhone).
   2. The extent to which this proposal will provide an out-of-the-box accessible solution.  Identify any additional effort required by the customer in order to procure or use all of the functionality offered by this solution.
   3. Information, including manuals, that Bell plans to supply in alternate formats (Braille or plain language, special labelling, etc.).
3. Explain what Bell means by “co-develop”. Provide specific details as to any agreement that you may have with a potential co-developer.
4. Provide the following details:
   1. The name of handset manufacturer and the name of the developer of the screen-reader functionality if different from the manufacturer;
   2. Details pertaining to brands, models, operating systems of the proposed handset(s) on which Bell plans to support this screen reader; and
   3. Details of the planned “co-development,” including:
      • Modifications, customizations and integration efforts; and
      • Adaptation required specifically for feature phones to work on Bell’s wireless network infrastructure. 
5. Explain with rationale why the approach of “co-developing” is preferable to other approaches for offering this solution, such as procurement of products similar in nature and functionality,⁴ available and/or offered in other jurisdictions (including the United States).  Include in your answer the cost considerations for each approach.
6. At paragraph 31, Bell states, “This will be developed and incorporated into feature phone handsets purchased from the supplier on an ongoing basis, making the initiative sustainable in the longer term.”
   1. Specify how long the proposed product will be made available to Bell customers; and
   2. Specify the measures that Bell plans to take to ensure that the screen reader capabilities are available on future generations of the proposed phone (or other feature phones), after product end of life, and after deferral account funds are fully utilized.
7. Explain how Bell will price the screen reader capability, including the device, services, discounts, contracts, mark-ups, etc.
8. At paragraph 38 of the Proposal, it is stated that Bell will “Co-develop a bilingual screen reader application with a major device manufacturer that can be ported and integrated into a manufacturer’s feature phones and /or smart phones.” Confirm whether the screen reader being developed will be available for use with feature phones AND smartphones. If affirmed, please answer all questions in the above section with regard to both feature and smartphones.

5.0  Mobile Accessibility

At paragraph 35, Bell states that it plans to procure and distribute Mobile Accessibility by Code Factory, a screen reader application for Android Smartphones, through its Accessibility Services Center to customers who request it.  Bell states that the addition of Mobile Accessibility to its device line up allows customers to select between a variety of Android handsets and that this implies an increased ability to select from a variety of price points, handset styles (e.g., those with a keyboard and those without) and brands of handset manufacturer because the Android operating system offers the variety that Apple does not. 

1. Does Bell plan to offer the “Mobile Accessibility” application integrated with an Android smartphone for an out-of-the-box accessible solution?
   1. If yes, does Bell plan to provide for customer and technical support in a similar integrated manner for both the application and the underlying smartphone?
   2. If no, identify the additional effort required by the customer in order to procure, integrate and operate this solution.  Explain how customers will receive technical and customer support for issues related to the Mobile Accessibility application.
2. Specify any limitations that users of this solution will have to full access of the functionality offered by the underlying Android smartphone.
3. Explain how Bell plans to price this solution, including the application, the smartphone, packages, discounts, contracts, mark-ups, etc.
4. Identify information for this solution, including manuals, that Bell plans to supply in alternate formats (Braille or plain language, special labelling, etc.)
5. With respect to sustaining this proposed solution:
   1. How long does Bell intend to sustain this product?
   2. Specify the measures that Bell plans to take in order to sustain into the future Mobile Accessibly screen-reader solutions (or next generation 3rd party screen-reading applications/software) on future smartphones, and after deferral account funds are fully utilized.
6. Provide costs, including any cost associated with license fees, etc.

6.0  Tecla Access

 A. At paragraph 37, Bell states that it has chosen the Tecla Access as “no other device was located that could meet the needs of people with moderate-to-severe physical disabilities that was also within a reasonable price range.”

1. Explain with rationale Bell’s view of a “reasonable price range.”  In your answer, provide the criteria that Bell uses to assess and establish a “reasonable price range”.
2. Provide examples of wireless handset solutions for persons with moderate-to-severe mobility disabilities that Bell has investigated and has decided not to offer for reasons pertaining to its view of a “reasonable price range”.  In light of these examples, explain why Bell considers the Tecla Access to be within a reasonable price range.

B. Provide a detailed description of how Bell’s proposed Tecla Access solution works from both a technical perspective and a user’s perspective. 

1. Specify any limitations that a user of Tecla Access would experience to full access of all of the capabilities offered by the underlying smartphone.

C. Identify all of the components that Bell plans to supply in its proposed Tecla Access solution, including those referenced in its application and listed below:

1. The Tecla Shield;
2. The Tecla App;
3. The underlying smartphone (Android or other); and
4. Mounting hardware.

D. Confirm whether any of the components critical to the effective use of the Tecla Access solution by persons with moderate-to-severe mobility disabilities that must be procured separately.   If yes:

1. Identify the components that Bell does not intend to supply, providing rationale;
2. Identify the source from which these components are to be procured; and
3. Describe the additional effort required by the customer in order to procure this solution in its entirety

E. Explain how Bell plans to price this solution, including the application, the smartphone, mounting hardware, packages, discounts, contracts, mark-ups, etc.  

F. At paragraph 37, Bell states that it will work with certified partners to ensure distribution, installation, integration and support. 

1. Identify Bell’s certified partners for this solution, and please provide further details as to who exactly will be responsible for ensuring distribution, installation, integration and support.
2. Explain whether this approach will provide for seamless support of Bell’s proposed Tecla Access solution as an integrated end-to-end solution.  If not, describe the additional effort required by customers for installation, operation, and customer and technical support.
3. Explain how this “partnership” approach will provide greater benefits and value to Bell’s Tecla Access customers in contrast to the online ordering approach currently offered by Komodo OpenLab.

G. With respect to sustaining this proposed solution:

1. How long does Bell intend to sustain its proposed Tecla Access Solution?
2. Describe in detail the measures that Bell plans to take to sustain its proposed Tecla Access solution on future generations of smartphones.  Include Bell’s plans for addressing areas that may put the sustaining of this solution on smartphones at risk.  These areas would include, for example, hardware and software interfaces, operating systems, application programming interfaces (APIs), critical accessibility features, etc. of the underlying smartphone.

7.0  Education and Awareness

At paragraph 40, Bell describes its plans for education and awareness.  Bell states that education and awareness will be promoted through a combination of highly targeted media campaigns as well as broader, mass media campaigns.  Programs specifically targeted towards people with disabilities will be employed by this initiative.

1. Of the overall amount that Bell has allocated for marketing campaigns, provide an allocation breakdown of funds for each of the proposed initiatives given in this application.
2. Provide a breakdown on each of the proposed campaigns.  Include type, focus, timing, and cost.  Specify the cost of each campaign and whether the campaign will be handled by Bell or a third party.  Indicate those campaigns that will be wholly directed to persons with disabilities using channels that uniquely target these people (Abilities magazine for example).
3. Explain how Bell plans to promote its products and services for persons with disabilities after deferral account funds are fully utilized.

8.0  Tutorials

At paragraph 45, Bell stated that it will create five tutorials across 35 devices that answer accessibility-related questions that the Accessibility Services call center currently receives.

1. Provide some examples of what might constitute an “accessibility-related” question.
2. Provide greater detail on the proposed tutorials, specifying the topic, the affected devices, etc.

9.0  The Selector

In Section 3.3.1 of its application, Bell described its “Web-based Accessible Handset Selector” (The Selector), and proposed it as a new feature to be deployed on the Bell.ca website.  According to Bell, The Selector will complement the handset selection functionality that is already present on Bell's website and will replace the limited accessibility information that is currently available on the Smartphones and Mobile Phones section of the Bell Accessibility Services Centre website. 

Bell stated that The Selector will help customers with disabilities to select a handset to meet their personal needs or preferences, and that it is anticipated that the Selector will help Bell call centre and in-store customer service representatives to provide more effective customer guidance in selecting a suitable handset. 

The Selector will be sustainable because it will operate on the basis of a pre-defined set of "key handset accessibility features" that will be collected as a routine part of Bell's standard handset procurement, and will be stored in Bell's standard handset product database.  Since the product information will be populated automatically at product launch, the information relayed to customers on Bell.ca will be the most accurate and up-to-date information available.  Additionally, it was determined that key pieces of handset information essential to making a purchase decision, were not readily available on Bell.ca or elsewhere. 

A. At paragraph 49, Bell states that The Selector will be deployed on the Bell.ca website.  Specify the location on the Bell.ca website where Bell plans to situate The Selector, with an explanation of why this location is appropriate for a feature of this nature.

B. Bell states at paragraph 51 that The Selector will be sustainable because it will operate on the basis of a pre-defined set of "key handset accessibility features" that will be collected as a routine part of Bell's standard handset procurement, and will be stored in Bell's standard handset product database.

a) Identify how Bell will determine what the “pre-defined set of key handset accessibility features” should be. Describe the process that Bell will use to identify the “pre-defined set of key handset features”.  Confirm that this process will include consultation with persons with disabilities (such as the Advisory Committee).

b) Provide Bell’s view as to the value that The Selector will provide to persons with disabilities that is not available in other online tools of similar functionality.  For example:

• The CWTA’s accessibility website, http://wirelessaccessibility.ca/find-devices/; and
• The Mobile Manufacturers Forum, Global Accessibility Reporting Initiative (GARI) http://www.mobileaccessibility.info/.

10.0  Bell.ca and Mobility Accessibility Improvements

In section 3.3.2, Bell proposed enhancements to Bell.ca and Mobility Accessibility Improvements. These entail update of the Bell.ca web site and the Bell self serve mobile application to WCAG 2.0 Level AA standards.

A. Explain why Bell has chosen to not implement the proposed website upgrade through deferral account funds allocated to improvements to the Bell Accessibility Services Centre, considering that the Commission’s policy on accessibility of websites has been in place since 2009.

B,. At paragraph 57, Bell stated that, “increased sign language-related information, such as information on how to make video conferencing calls, will be added to Bell.ca/Accessibility. This will also include group names and select headings listed in American Sign Language (ASL) and Langue des Signes Québécoise (LSQ). ”  Clarify as to whether Bell is proposing to provide some form of online sign language (ASL and/or LSQ) capability to convey the above type of information.

C. At paragraph 59, Bell proposes accessibility improvements to Bell.ca that will improve the customer experience and listed the following as a selection of web pages deemed "essential" that will undergo accessibility changes to conform to WCAG 2.0 Level AA standards, where necessary.  At paragraph 60, Bell stated that the “Bell Self-Serve mobile application was identified as an essential component of the Bell user experience.”

• Bell Mobility Home;
• Store Locator;
• Bell.ca template;
• My Bell;
• Build Your Own Solution;
• Bell Networks;
• Bell Superphones;
• Bell Fibre;
• Bell Mobile TV;
• Bell Bundles;
• Bell Support;
• Bell Accessibility Services; and
• Bell Support chat functionality.

1. On what basis were these web pages “deemed essential”.
2. Refer to Bell Canada(CRTC)8Feb11-1001, Bell’s interrogatory response for its submission of 18 January 2011 (Attachment C).  Explain how the website upgrade proposed in this application is consistent with the accessibility objectives of the Mobility Accessibility Initiative detailed in that response, including details as to how this proposed upgrade to Bell.ca fits with any of the Key Initiatives given in Table 1 of that response.
3. In the absence of deferral account funding, does Bell plan to make the proposed accessibility changes to its website anyway?

11.0  Remote Device Manager (RDM)

At section 3.4.2, Bell proposed to equip its technical support staff with a Remote Device Manager (RDM) that would allow staff to assist customers in troubleshooting problems in devices from a remote location.  With the customer’s permission, the RDM tool will give customer service representatives access to a customer’s device interface so that the customer service representative can then identify and solve problems more quickly and easily.

1. Specify whether RDM will be used to support Bell devices and/or services other than mobile wireless handsets and services? 
2. Specify any limitations with respect to the use of RDM for feature phones smartphones currently supported by Bell, including the accessibility solutions proposed by Bell in this application.
3. Confirm whether Bell plans to deploy RDM to support its entire customer base. 
4. Explain what Bell means by this statement at paragraph 73 that the “RDM will be made fully accessible across all devices at any given time.” 
5. Specify any provisions or customizations of product or procedures that Bell intends to make with respect to the RDM to address the specific accessibility needs of customers with disabilities.  Specify the associated costs.  Would Bell make these provisions or customizations in the absence of deferral account funds?

12.0  Lifecycle

In section 3.2.3, Bell describes its proposed approach to Lifecyle Management which entails a dedicated Product Manager and Project Manager for the accessibility portfolio of handsets to maintain accessibility from procurement to product launch to End of Life (EOL).  Bell stated that the Product Manager will work to ensure that the accessibility features and/or applications Bell provides as a result of this proposal are maintained on handsets in the future, and that compatibility, training and support are provided if a need is established.  The Project Manager will carry out project-related deliverables described within Bell’s application to completion, and will act as a key accessibility influencer and advocate with the corporate environment. 

1. Refer to Bell Canada(CRTC)8Feb11-1001 D2006-9, Bell’s interrogatory response for its submission of 18 January 2011 (Attachment C) which states amongst other things, “This project will also allow the Company to drive the momentum for making long term and sustainable business changes, in a variety of areas, that influence its systems, processes, and procedures that manage day-to-day operations.  These business changes will support the integration of accessibility into Bell’s processes and daily and operational culture.  Ensuring this understanding and business practices are infused into all aspects of the organizational processes and practices will, by extension, be reflected outwards to our customers.”
   1. Provide the name of the person in Bell’s executive management who is responsible for ensuring that the business and operational changes that support the integration of accessibility in Bell’s processes and operational daily cultural, as referenced in more detail above, will occur and will be sustained in the long-term.
   2. Provide evidence that demonstrates that these business and organizational changes are actively being addressed corporate-wide and throughout all levels of the organization.
2. Explain with evidence how the approach will ensure that accessibility products and processes resulting from the implementation of the proposals given in Bell’s application will be sustained in Bell’s operations after deferral account funds are depleted.  Support your answer with relevant documentation.
3. Explain with evidence how the approach will allow customers with disabilities to experience seamless transition of accessibility capabilities and features to future generations of mobile products and services, including those proposed in this application. 
4. Will the Product Manager and/or Project Manager be accountable for evolving Bell’s accessibility portfolio of mobile products and services, as new capabilities become available on the market in order to offer its customers with disabilities more choices and options.

13.0  Procurement

At section 3.4.4, Bell describes its proposed procurement process.  The process described includes encouragements to handset manufacturers to include accessibility improvements in key devices.  Bell stated that key features⁵ used by The Selector should be highlighted because these will be used to filter product offerings.

1. Of the features listed by Bell’s as its procurement criteria, specify those that are not commonly available on Bell’s mobile wireless offered to its general base of customers.
2. Provide the detailed reporting pertaining to “evaluation criteria/process to establish objective and measurable success criteria” as directed by the Commission in its letter to Bell dated 29 April 2011.

14.0  Universal/Inclusive Design

Provide detailed reporting pertaining to “Methodology for implementing universal/inclusive design” as directed by the Commission in its letter to Bell dated 29 April 2011.  This should include but not be limited to the following:

1. An overview of Bell’s universal/inclusive design methodology, providing examples from Bell’s internal documentation or processes for greater detail. 
2. Bell’s view as to how the initiatives set out in this application are embodied within the above-referenced methodology, specifying how this approach serves as “a flagship example of successful implementation of accessibility through inclusive design.”⁶

15.0  Other

Refer to the following paragraphs of Telecom Decision 2010-637:

• At paragraph 15, the Commission noted that Telecom Decision 2002-34 specifically provides that amounts in the deferral accounts will bear interest at the ILECs' short-term cost of debt, which is to be determined annually, and that no subsequent Commission decision has indicated that this practice should cease. 
• At paragraph 17 the Commission noted that Telecom Decision 2005-69 extended the deferral account regime as a whole until 31 May 2007. However, the Commission noted that the extension did not single out particular elements of the regime for different treatment, as suggested by the Bell companies. In addition, Telecom Decision 2007-27, which ended the application of the deferral account mechanism going forward, did not eliminate obligations under the existing deferral accounts, including the accumulation of interest and of any remaining recurring amounts.
• At paragraph 19 the Commission stated that it considers that the ILECs' deferral accounts should continue to accrue interest and recurring amounts beyond the date proposed by the Bell companies. The Commission considers that this methodology recognizes the full value of the funds in the accounts, and that to permit otherwise would allow the ILECs to benefit from, in effect, interest-free loans.”

Bell Canada                                                                                         Response to Interrogatory
22 February 2011                                                         Bell Canada(CRTC)8Feb11-1001 D2006-9

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INFORMATION REQUESTED BY
CANADIAN RADIO-TELEVISION AND TELECOMMUNICATIONS COMMISSION

 

Q. Provide the following information:

 

1. The overarching accessibility objectives that Bell Canada (the Company) plans to achieve with the proposal in this application;
2. Expected overall outcomes and benefits with illustrating examples;
3. 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
4. How the principles of universal/inclusive design and accessibility will be applied to the expected outcomes.

A.          a)           The Company’s proposal will enhance accessibility by going beyond the mere availability of mobile devices; the proposal supports staff and customer awareness, informed choices, ongoing use and future diversity of accessible mobile telecommunication choices.  The Company’s proposal will go beyond the Commission’s requirement for each mobile telecommunications company to carry a single accessible mobile device.  The Company’s proposal will result in a variety of accessible devices being made available to consumers with knowledgeable Company Service Representatives able to ensure that customers accessibility needs are matched to an appropriate mobile telecommunications device.

Through feedback and information gained from advocacy groups, previous proceedings and customer complaints, the Company suspects that in many situations, it has the devices and applications that may address some accessibility needs but lacks the awareness of these features in its wireless mobile handsets and how they could assist specific individuals.  Thus, in some situations, unmet needs and underserved needs may arise not from a lack of accessible devices and applications in the Company’s inventory, but instead from a lack of information and understanding on how to recommend appropriate features.

In other cases, there may be a gap in the Company’s inventory to address a need that could be dealt with through procurement, but the Company is unaware of what it should be looking for as part of the procurement process.  Similarly, persons with disabilities often have a clear understanding of their accessibility issues but lack a clear understanding of the technical measures that will assist them with respect to wireless mobile communications.

The Company is proposing to work together with advocacy groups and accessibility experts to ensure a rapid and significant improvement to accessibility for mobile telecommunication products, services and support, and to develop packages, applications and services that meet the requirements of customers with disabilities.  The Company does not have expertise in this area and anticipates that an accessibility expert will be required to conduct a review of all available solutions.  In particular, the Company will request an analysis of:

1. Solutions that are not currently in the Company’s inventory, whether these solutions are offered by suppliers that the Company has an existing relationship with or by suppliers that the Company does not currently deal with, and
2. Solutions that other WSPs offer that the Company may want to adopt.

The Company is proposing to develop an advanced level of internal knowledge through training and workshops at all levels within the organization.  This knowledge is required in order to drive a culture of awareness regarding accessibility needs, products, services and support.  This project will also allow the Company to drive the momentum for making long term and sustainable business changes, in a variety of areas, that influence its systems, processes, and procedures that manage day-to-day operations.  These business changes will support the integration of accessibility into the Company‘s processes and operational culture.  Ensuring this understanding and business practices are infused into all aspects of the organizational processes and practices will, by extension, be reflected outwards to our customers.

Table 1 – Outcomes and Benefits of the Five Key Initiatives

Key Initiative	Outcome	Benefit
Web Tools	Through stakeholder and consultant input, develop a new web-based, high quality and accessible product search and recommendation tool. This will provide improvements to availability of information regarding available accessible device features, services, applications and accessories.	Simplify, streamline and improve product information and search capabilities for internal teams, retail stores, and consumers. Deliver customized recommendations to support informed choices and enable independence for persons with disabilities.
Marketing Distribution and Channels	Work with stakeholders and consultants to define the best current and / or alternate channels for distribution, support, outreach and marketing activities.  For example, working directly with current advocacy retail entities.  Expand specific product & services knowledge and capabilities through participation in appropriate events and trade shows.	Increased awareness both internally and externally regarding the Company’s commitment to accessible mobile products and services.  Open new avenues for localized provisioning, activations, and support that are relevant to persons with disabilities.
Lifecycle Management	Incorporate into our internal processes accessibility considerations where upgrades or changes in software and hardware are inevitably required.  Refine engineering device requirements that will improve consistency across device, application & accessory platforms.  This will provide customers with an improved experience where devices & services are more compatible or easily upgraded.  For example; work jointly with device manufacturer and the Company’s engineering & procurement teams to ensure the technical and functional aspects of devices are consistent throughout product line up.  Adherence to minimum device requirement standards currently exists for all manufacturers.  This is regularly reviewed and can be updated by the Company’s teams to capture items of interest to accessibility support.  This will allow for improved compatibility of software and accessories across multiple devices and operating systems.  For example; screen reader applications that are transferrable from older to newer devices at no additional costs.  Loopset headset models that consistently support the evolution of Bluetooth specifications.	Ensure the transition of a device, accessory or application is seamless across new hardware and software platforms.  When upgrades or new devices are required reduce the need to "re-purchase" a specific item to maintain current functionality.
Procurement	The Company is looking to incorporate universal/inclusive design principles into its mobile phone product procurement criteria to obtain products and services that have been developed to support accessibility without the need for adaptation or after-market modifications.	Provides a continuous supply of accessible devices, features, and applications into the Company’s mobile phone inventory supported by sustainable procurement practices.
Unmet Needs/ Developing Solutions	Through Stakeholder collaboration and expert advice identify unmet needs that are reasonably within the Company’s scope and select one or two priorities to address. Access solutions that are appropriate to implement.	Address one or more priority needs.

Second, the Company plans to meet with the Advisory Committee at 6 months and 18 months after the initiatives are launched with the specific purpose of obtaining the committee’s perspective on the success of initiatives, relevance to their members and the extent to which the outcomes address the needs identified by the stakeholders.  The meetings will also discuss the results of end-user feedback questionnaires.

Generally the principles of Inclusive or universal design are defined as follows⁷:

1. Equitable Use: The design does not disadvantage or stigmatize any group of users.
2. Flexibility in Use: The design accommodates a wide range of individual preferences and abilities.
3. Simple, Intuitive Use: Use of the design is easy to understand, regardless of the user's experience, knowledge, language skills, or current concentration level.
4. Perceptible Information: The design communicates necessary information effectively to the user, regardless of ambient conditions or the user's sensory abilities.
5. Tolerance for Error: The design minimizes hazards and the adverse consequences of accidental or unintended actions.
6. Low Physical Effort: The design can be used efficiently and comfortably, and with a minimum of fatigue.
7. Size and Space for Approach & Use: Appropriate size and space is provided for approach, reach, manipulation, and use, regardless of the user's body size, posture, or mobility.

   Considerations to these principles will be a primary focus throughout Delivery A and B of the proposal.  The principles are applied to the design to minimize exclusion.

   As an example for the Web Tool:

   Is the web tool equitable in use, if I have vision loss, can’t hear or have trouble simply knowing what I want?  Is the tool a valuable resource for the widest audience possible?

   Is the web tool simple and intuitive?  As designed then tested with various users who may have limited technical or internet skills or have a intellectual disability will they be able to navigate without instruction or feedback to achieve a desirable result?

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[1] /PartVII/eng/2011/8678/b2_201100594.htm, 2012-01-16 – Bell Canada.

[2] /PartVII/eng/2011/8678/b2_201100594.htm.  See 2011-02-11 – Bell Canada, Bell Canada(CRTC)8Feb11-1004_ABR.

[3] /PartVII/eng/2011/8678/b2_201100594.htm.  See 2011-01-18 – Bell Canada, item 110118-BC-Dec. 2006-9 Proposal_ABR, paragraph 15.

[4]  For example, the Samsung Haven is available from service providers in United States.

[5]  Features listed:

• Candy bar shape;
• Full QWERTY Keyboard;
• System-wide adjustable fonts and colours (fonts, font size, foreground colour, background colour, letter spacing, line spacing);
• System-wide magnifier;
• Voice output;
• System-wide screen reader (with emphasis on end-to-end control);
• External Braille display support;
• Hearing Aid Compatibility (HAC) (especially towards T4/M4 on Bell's networks);
• Video-conferencing (especially with good sign language video quality on Bell's networks);
• Silent alerts and indicators that apply to applications (especially if they customizable in terms of strength, duration, and pattern);
• Voice recognition (with emphasis on end-to-end control and minimal physical contact with touch screen and/or physical buttons);
• Stylus support (including for buttons that are often side-facing such as on/off/sleep);
• External keyboard support (with emphasis on end-to-end control);
• External mouse support; and
• External switch support (with emphasis on end-to-end control by single-switch and multi-switch users).

[6] /PartVII/eng/2011/8678/b2_201100594.htm.  See 2011-02-22 – Bell Canada.   Interrogatory Response, Bell Canada(CRTC)8Feb11-1002, Item A.

[7] The Center for Universal Design.  (Centre for Universal Design 2007), Copyright 1997 NC State University.