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Ottawa, 13 September 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:  Deferral Account Proposal to Improve the Accessibility of Mobile Devices and Services – Request for extension for filing interrogatory responses and for further process

Dear Mr. Abbott:

I am writing in response to your letter dated 31 August 2012 that requested a 60-day extension for Bell Canada’s (the Company’s) filing of interrogatory responses for the above-referenced deferral account initiative (the Mobility Accessibility Initiative) to which the Company had previously allocated $6.5M in deferral account funds. 

The Company submitted that the extension is required because of a change in the Company’s proposal that was both unforeseen and outside of its control.  The Company had proposed to allocate $1.5M of the $6.5 M for the development of an accessible bilingual screen-reader to be used with a type of ‘feature’ wireless handset.  However, the handset manufacturer with whom the Company had been working recently informed the Company that it was no longer interested in the project for a number of reasons.  As a result, the Company proposes to reallocate the $1.5M to alternative initiatives.

The Company requested at least 60 days to develop these alternative initiatives and review them with the Advisory Committee.  The Company submitted that the Commission’s interrogatories are so inter-linked that it is not possible to respond to the interrogatories with respect to the $5.0M of allocated initiatives and file the response to the alternative initiatives for $1.5M at a later date.  Thus the Company submits that the only practical avenue for addressing the matter of the $1.5M is to extend all of the filing dates in this matter by 60 days.

In light of the given circumstances, Commission staff amends the dates for the Mobility Accessibility Initiative filings as follows.

Note:  In addition to Bell Canada, interrogatories are addressed to the following parties:  The Canadian Council for the Blind, the Canadian Hearing Society, the Canadian National Institute for the Blind, the Ontario Association of the Deaf, and the Neil Squire Society.

Bell Canada is reminded that any alternative initiative(s) that it proposes to replace the bilingual screen-reader initiative is to be consistent with the Commission’s letter dated 29 April 2011 that approved deferral account funding for Delivery A (planning) of the Mobility Accessibility Initiative  including detailed reporting in the following areas:

In addition, for efficiency of process, Bell Canada is to take guidance from the Commission’s 10 August 2012 interrogatories in regard to the nature of information and level of detail required when providing information to the Commission for approval of any alternative initiatives(s) that it proposes to replace the bilingual screen-reader.



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


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