ARCHIVED - Telecom Commission Letter addressed to Stephen Schmidt (TELUS Communications Company (TELUS))

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Ottawa, 15 October 2014

File No. 8678-T66-201406075

Mr. Stephen Schmidt
Vice-President – Telecom Policy & Chief Regulatory Legal Counsel
Telecom Policy & Regulatory Affairs
TELUS Communications Company (TELUS)
215 Slater Street, 8th Floor
Ottawa, Ontario, K1P 0A6

By email:

Re: Part 1 Application - Deferral Account Proposal to Improve the Accessibility of Telecommunications Services for Persons with Disabilities

Dear Mr. Schmidt:

I am writing in regard to the above TELUS Communications Company’s (TELUS) deferral account application filed with the Commission on 30 June 2014 (the current application). This letter is further to Commission staff letter dated 25 July 2014, where TELUS and interested parties were notified that the normal comment and reply deadlinesFootnote 1 for this application were suspended to allow Commission staff to further review TELUS’ application.

On 8 October 2014, the Commission published Telecom Decision CRTC 2014-527, regarding Bell Canada and Bell Mobility Inc.’s (Bell) deferral account proposal. In light of this decision, please confirm whether or not you wish to proceed with the current application, as filed. If no, please advise the Commission by 22 October 2014 when TELUS will file a new application.

Should you wish to proceed with the current application, as filed, please provide responses to the questions below by 29 October 2014.

  1. The current application follows a previous application filed by TELUS on 29 April 2013 (8678-T66-201306845 (the previous application)), both of which sought approval to spend the remaining 2.7 million dollars of TELUS’ deferral account funds on proposed initiatives. Given the time elapsed between these applications, as well as between the filing of the current application and the publication of the deferral account funds decision of 2008, please explain why:
    1. 1 million dollars worth of funds would remain to be allocated according to the current application, if the current application were to be approved, and
    2. TELUS has chosen to proceed with the current application given that it does not propose to use the totality of the remaining deferral account funds.
  2. Commission staff has conducted a review of TELUS’ current application, and has identified significant similarities between the previous and the current application. Given these similarities, it is proposed that the record of the previous application be appended to this application in order to create efficiencies in processing the current application.
    1. Comment on the above proposal, and
    2. Clearly identity and describe those specific areas, if any, where its position has changed since the previous application, providing substantiating rationale.
  3. Refer to Paragraph 47 the letter accompanying the current application, dated June 30, 2014, and:
    1. Describe the planned accessibility audit activities, and
    2. Provide a further breakdown of the internal and external time estimates.
  4. Refer to Table 5 of Appendix D of the current application, where TELUS requested the Commission to approve “$1,223,000” to implement the proposed changes to its websites.

    Commission staff notes that TELUS’ current deferral account proposals amount to $728,567. Explain why TELUS is requesting the Commission’s approval to drawndown the deferral account for an amount that is greater than the total of the company’s proposals.

Should you have any questions regarding this letter, please contact Marie-Claire Bouthillier at 819-997-4692 or .

Yours sincerely,


Nanao Kachi
Director, Social & Consumer Policy
Consumer Affairs and Strategic Policy


Distribution List:

Eric Edora; Canadian Association of the Deaf; Ontario College of Art and Design, Treviranus,;  ARCH;  Council of Canadians with Disabilities,; Council of Canadians with Disabilities,; Independent Living Canada,;  Canadian National Institute for the Blind (CNIB),;;; Canadian Council of the Blind,; Ottawa Deaf Centre,; Ontario Association of the Deaf,; The Canadian Hearing Society,; Canadian Association for Community Living,; Centre québécois de la déficience auditive,; Public Interest Law Centre,; Disability and Information Technologies (Dis-IT),;; Alliance for Equality of Blind Canadians/L'Alliance pour l'égalité des aveugles canadiens,;; Neil Squire; Society,;  Chris Stark,;; Clayton Zekelman, clayton@MNSi.Net; Beverley Milligan, Media Access Canada,; Confédération des organismes de personnes handicapées du Québec,;

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