ARCHIVED -  Letter

This page has been archived on the Web

Information identified as archived on the Web is for reference, research or recordkeeping purposes. Archived Decisions, Notices and Orders (DNOs) remain in effect except to the extent they are amended or reversed by the Commission, a court, or the government. The text of archived information has not been altered or updated after the date of archiving. Changes to DNOs are published as “dashes” to the original DNO number. Web pages that are archived on the Web are not subject to the Government of Canada Web Standards. As per the Communications Policy of the Government of Canada, you can request alternate formats by contacting us.

Ottawa, 5 August 2013

File No.: 8678-C12-200905557

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

Re: Inclusive Design Initiative, a deferral account accessibility initiative of Bell Aliant Regional Communications, Limited Partnership and Bell Canada

Dear Mr. Abbott:

Commission staff has reviewed the file to date of the Inclusive Design Initiative of Bell Aliant Regional Communications, Limited Partnership and Bell Canada (collectively “Bell”) and is writing to request Bell to file responses to the questions set out in the attachment to this letter. Bell last reported on the Inclusive Design Initiative in its 30 March 2012 annual report on accessibility initiatives funded from the deferral accounts, as approved in Telecom Decision 2008-1.

In Decision 2008-1, the Commission approved Bell’s Inclusive Design Initiative as an initiative to improve access to telecommunications services for persons with disabilities. As Bell stated in its initial proposals, the objective of the Inclusive Design Initiative is “to gain a greater understanding of the telecommunications needs of persons with disabilities and to incorporate inclusive design principles into new product development. This approach will assist Bell Canada to design new products and services that have both mass market appeal and improved usability and functionality for persons with disabilities.”

As Bell further described the initiative in its 2012 annual report, “[u]ltimately, this initiative provides insights that allow the Companies to incorporate inclusive design principles into their everyday operations.”

In its 2012 report, Bell also stated that its Inclusive Design Initiative was complete.

Please provide your responses to the questions in the attachment no later than
30 Aug 2013.

Bell’s 2006 proposal:

Record of the 2008-1 proceeding:

Bell’s annual reports:



Mary-Louise Hayward for
Nanao Kachi
Directeur | Director
Politique sociale et des consommateurs | Social and Consumer Policy
Consommation et politiques stratégiques | Consumer Affairs and Strategic Policy
819- 997-4700.

1. In Decision 2008-1, the Commission approved Bell’s Inclusive Design Initiative, satisfied that it met the guidelines established in 2006-9 for the disposition of funds remaining in deferral accounts. These guidelines specified that initiatives must improve accessibility to telecommunications services for persons with disabilities.

Staff notes from Bell’s website that Bell FibeTM TV is marketed and sold as a TV service. In its 2012 annual report, Bell stated that “[a]s a result of this [Inclusive Design] initiative the Companies were able to identify possible areas for improvement for the Companies’ IPTV services in Ontario and Québec that would enhance access to communications services for persons with disabilities.” The 2012 report also stated that in achieving this result, Bell had participated in a working group for users of Microsoft Mediaroom (the platform that delivers Bell Fibetm TV) where Bell had reviewed Design Change Requests (DCRs) for the Mediaroom platform and proposed these to Microsoft for consideration as possible areas for improvements in accessibility. The report also included the final draft DCRs. An amount of deferral account funding slightly higher than the $1.08M was utilized for this initiative.

a. Provide your view with substantiating detail as to how the use of deferral account funds approved by the Commission for initiatives to improve accessibility to telecommunications services is appropriate for a TV service.

b. Refer to the table on page 15 of Bell’s 2012 annual report. Provide a status update for the implementation of each design change into the Microsoft Mediaroom platform, identifying any barriers that have prevented implementation.

2. The section of Bell’s 2012 annual report dealing with the Inclusive Design Initiative states that research to assist in incorporating inclusive design principles into new product development was done in the following areas:

i. general telecom;
ii. enhanced customer services;
iii. IPRS
iv. voice dialling
v. subject matter expert study
vi. IPTV assessment; and
vii. corporate accessibility audit

a. Provide an explanation of how this research has been used by Bell. In particular, identify those inclusive design principles that Bell has incorporated into its everyday operations and explain how Bell has done so. Confirm that these are actively in use. Provide examples of ‘inclusively designed’ telecommunications products and services that Bell has delivered through the application of these principles.

b. Alternatively, if Bell has not incorporated this inclusive design approach into its everyday operations, explain why, with substantiating rationale.

Date modified: