ARCHIVED - Telecom Commission Letter addressed to Frank Folino (Canadian Association of the Deaf), Jonathan Daniels (Bell Canada) and Gary Birch (Neil Squire Society)
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Ottawa, 1 August 2014
File no.: 8665-C12-201403287
By email:
Frank Folino cad@cad.ca;
Jonathan Daniels bell.regulatory@bell.ca;
Gary Birch garyb@neilsquire.ca
RE: Submission made by the “pre-incorporation Interim Board of Directors of the VRS Administrator” as part of the proceeding Telecom Notice of Consultation CRTC 2014-188
Dear Sirs,
The Commission received your proposal submitted as part of Telecom Notice of Consultation CRTC 2014-188 (TNC 2014-188) on 25 July 2014. Your proposal is available online for the public to view and comment on until 28 August 2014 at www.crtc.gc.ca. In paragraph 6 of TNC 2014-188, the Commission set out its expectation that proposals would include, at a minimum:
- a draft application for incorporation, including a proposed statement for the purpose of the corporation;
- a draft bylaw, including a proposed selection process for the Board of Directors, a proposed governance structure, and mechanisms to address any real and potential conflicts of interest;
- a draft stakeholder agreement, including the mandate of the VRS administrator;
- proposed funding application processes for VRS;
- proposed measures to ensure financial accountability;
- detailed proposed reporting requirements for the VRS administrator to report to the Commission, including information related to financial accountability;
- an explanation of how the proposal incorporates the viewpoints of the different groups consulted in its development; and
- a proposed implementation timeline, including timelines for the submission of key documents to the Commission, such as
- applications for funding;
- financial accountability measures;
- quality of service measures;
- complaint and inquiry mechanisms for the VRS administrator and for any VRS providers;
- an education and public awareness campaign; and
- privacy and confidentiality standards.
On 13 May 2014 the Commission received a procedural letter jointly signed by Bell Canada and the Canadian Association of the Deaf (CAD) requesting an extension for the deadline to submit proposals from 22 May 2014 to 25 July 2014, as well as subsequent deadlines to reflect these changes. Bell Canada and the CAD indicated that they would not be able to submit a proposal as outlined in paragraph 6 of TNC 2014-188 and consult consumer stakeholder groups by 22 May 2014. An estimate of 10 weeks was provided as the timeframe in which Bell Canada and the CAD could:
- Establish a detailed consensus proposal for structure, mandate, and governance of the VRS Administrator, including the Board composition and election process, funding application process for VRS, financial accountability measures, reporting requirements and a timeline for further work necessary to implement VRS.
- Develop a high level presentation on the interim board's proposal for use in consultation with prospective user groups and other VRS stakeholders.
- Conduct broad consultation with prospective user groups and other VRS stakeholders across Canada, in English and French and involving ASL and LSQ service.
- Draft submission, taking into account input received through the broad consultation with prospective user groups and other VRS stakeholders.
- Draft application for incorporation of the VRS Administrator and related documents.
The Commission therefore granted an extension, as detailed in Telecom Notice of Consultation CRTC 2014-188-1 to provide sufficient time for consultation with consumer stakeholder groups and the preparation of submissions.
Given that the Commission expects that any proposal will include the information set out in paragraph 6 of TNC 2014-188 and that in their letter of 13 May 2014 CAD and Bell Canada indicated that the requested extension would allow them to carry out the listed tasks, including drafting the application for incorporation and related documents, Commission staff requests that the “pre-incorporation Interim Board of Directors of the VRS Administrator” submit the information as outlined in paragraph 6 of TNC 2014-188 by 14 August 2014. Staff considers that keeping to the schedule set out in TNC 2014-188-1 is necessary to prevent delays in the implementation of VRS in Canada.
Should you have any questions regarding this letter, please contact Kay Saicheua at (819) 934-1358 or kay.saicheua@crtc.gc.ca.
Yours truly,
Nanao Kachi
Director, Social and Consumer Policy
cc: kay.saicheua@crtc.gc.ca
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