ARCHIVED -  Letter

Mr. Denis E. Henry
Bell Aliant
Vice-President – Regulatory, Government Affairs and Public Law
160 Elgin Street
Ottawa, Ontario
K2P 2C4
bell.regulatory@bell.aliant.ca

— AND—
Mr. Bill Abbot
Bell Canada
Senior Counsel & Bell Privacy Ombudsman
160 Elgin Street
Ottawa, Ontario
K2P 2C4
bell.regulatory@bell.ca

Subject: Bell Canada and Bell Mobility (collectively Bell) – Deferral Account Proposal to Improve the Accessibility of Mobile Devices and Services (the Mobility Accessibility Initiative) 8678-B2-201100594.

Dear Sirs:
This letter requests Bell to file a Part 1 application for approval of the second phase of its proposed Mobility Accessibility Initiative with the Commission on or before 29 April 2013, pursuant to the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules), serving it on the enclosed list of parties.
Background
In its Mobility Accessibility Initiative, Bell proposes to utilize $6.5M of its deferral account funds for the purpose of meaningfully improving the accessibility of mobile communications provided by Bell Canada and its affiliate Bell Mobility. The first phase of the Mobility Accessibility Initiative, the planning phase, was approved by the Commission in a letter dated 29 April 2011. In that same letter, the Commission directed Bell to file on 3 October

2011 its application for Commission approval of the second phase, the implementation phase.
Commission staff was informed by Bell in October of 2011 that there would be a delay in filing the application, and to date the second phase of the Mobility Accessibility Initiative continues to experience delays. As of March 2013, a Part 1 application has yet to be submitted and Bell is requested to file a Part 1 application.
Part 1 Application
Bell’s application is to address the following deliverables of the Mobility Accessibility Initiative identified in its original submissions and to reflect the responses it provided on 13 November 2012 to Commission staff’s requests for information:

• Screen-reader capabilities (i.e., handsets with a built-in screen-reader, Mobile Accessibility software, etc.);
• Tecla Access;
• The Selector;
• Mobile Remote Device Management (RDM);
• Education and Awareness (including text to 9-1-1);
• Website Modification;
• Customer Care, Training and Support, Lifecycle Management, Procurement; and
• Bell’s Mental Health Initiatives.

In addition to the above, Bell is to ensure that the Commission’s requirements as set out in its letter dated 29 April 2011 are addressed when it submits its application.
Commission staff reminds Bell that its documents need to be designed to be easily used by persons with disabilities. With that in mind, Bell is to:

1. Ensure that any overview document provides clearly and in one place the details pertaining to Bell’s Mobility Accessibility Initiative.

2. To facilitate the use of screen readers, Bell is to ensure that it uses a consistent lay-out for responses to staff requests for information. For example, the manner in which Bell references information contained in other sources should be consistent throughout its application. Bell is to also rectify the typographical errors that result in the linking together of discrete words into indiscernible strings of characters.

3. To “package” and label the “electronic” files of this application in a manner that streamlines and increases “accessibility of use” of the documents filed. Accessibility of use entails clear naming convention for all of the elements, such as Appendices and Attachments, that all of the elements are referenced in such a way that all persons, including those with disabilities, are able to navigate the files and assemble the application.

Sincerely,

Steven Harroun
A/Director General
Strategic Policy Directorate
Consumer Affairs and Strategic Policy
819-997-4546, steven.harroun@crtc.gc.ca

cc.: nanao.kachi@crtc.gc.ca
mary-louise.hayward@crtc.gc.ca
jonathan.daniels@bell.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), Christine.robbins@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; jeff.in.kanata@gmail.com; Clayton Zekelman, clayton@MNSi.Net; Ms. Denise Sayer, denise.sayer@paliareroland.com; Mr. David Lepofsky dlepofsky@sympatico.ca; Beverley Milligan, Media Access Canada, bmilligan@mediac.ca; Confédération des organismes de personnes handicapées du Québec, direction@cophan.org

Date modified:

2013-03-28