ARCHIVED - Telecom Commission Letter addressed to Philippe Gauvin (Bell Canada)

Ottawa, 22 May 2019

Our reference: 8678-C12-200905557

BY EMAIL

Mr. Philippe Gauvin
Assistant General Counsel 
Bell Canada 
160 Elgin Street, Floor 19
Ottawa, ON K2P 2C4 
bell.regulatory@bell.ca

Re: Decision 2014-527 and Decision 2015-563 – Annual Status Report on the Deferral Account-Funded Accessibility Initiatives – Request for information

Dear Sir:

The Commission is in receipt of Bell Canada’s Annual Status Report on the Deferral Account-Funded Accessibility Initiatives dated 29 March 2019. Commission staff have reviewed the report and acknowledges the positive impact Bell Canada’s use of its deferral account funds has had in improving access to telecommunications services for persons with disabilities. Of particular interest in 2018 were the creation of a new basic package which included a headset offered free of charge with the purchase of a subsidized Doro phone and the lifecycle management initiative which extended the end of life of the Doro 824 and 824C Doro phones. In Commission staff’s view, this demonstrates a commitment on the part of Bell Canada towards its customers with disabilities.

However, a review of the information submitted by Bell Canada concerning the “Third Party App Developer Program” has identified a number of gaps that do not allow for a comprehensive assessment of the initiative. Therefore, Bell Canada is asked to file an answer to the questions included below on or before 7 June 2019.

Context

In Telecom Decision 2006-9, the Commission determined that accessibility to telecommunications services for persons with disabilities is an important public policy objective and that using funds from the deferral accounts will help provide telecommunications services to these Canadians. Further to this, the Commission approved in Telecom Decision 2008-1 the use of deferral account funds by incumbent local exchange carriers for certain initiatives to improve access to telecommunications services for persons with disabilities. In Telecom Decision 2014-527 and Telecom Decision 2015-563, the Commission approved further initiatives for the use of deferral account funds by Bell Canada for this purpose.

More specifically, in Telecom Decision 2015-563, the Commission approved the use of Bell Canada’s deferral account funds to establish a Third-party App Developer Program devoted to improving the accessibility of the Bell companies’ mobile wireless smartphones and devices. The intent was for the program to “[…] include activities that would proactively engage third-party developers and increase their awareness of the interfaces available for accessibility development on the smartphones offered by the Bell companies”. ^Footnote1 Furthermore, in that decision, and consistent with the reporting structure determined in Telecom Decision 2014-527, the Commission directed Bell Canada to report annually, beginning in 2015 and until the deferral account funds are fully used, on the approved initiatives and to “[…] include details concerning the initiatives approved in this decision” ^Footnote2 . In addition, the Commission directed Bell Canada to provide a plan for the Third-Party App Developer Program in its 2016 Annual Status Report on the Deferral Account-Funded Accessibility Initiatives to fully utilize the allocated amount for the program by the end of 2019. The plan would include the following information:

• the number and type of accessibility contests and prizes;
• the number and type of accessibility hackathons;
• the number and type of accessibility partnerships; and
• the number and type of accessibility events; and
• a communications plan and strategy to proactively promote the events and engage third party developers. ^Footnote3

In reviewing Bell Canada’s 2019 Annual Status Report on the Deferral Account-Funded Accessibility Initiatives, Commission staff note that while the Third-party App Developer Program was launched in September 2016, an app has yet to be offered by Bell Canada, although the Company states that it expects to offer “at least the first app later this year”. To this end, Bell Canada states that “Due to a number of reasons, the app developer projects are taking longer to plan and implement than we had initially anticipated” and that because of this it was, “[…] not able to use any of the deferral account funds in 2018 for this initiative”. Moreover, Commission staff also note that the program described by Bell Canada in its Annual Status Report appears to be more passive than the proactive engagement with third-party developers that was set out by the Commission in Telecom Decision 2015-563.

Questions

1. Commission staff note that Bell Canada’s Annual Status Report on the Deferral Account-Funded Accessibility Initiatives dated 29 March 2019 does not explain why the Third-party App Developer Program is taking longer to plan and implement. Please explain in detail the “number of reasons” the Third-party App Developer Program is taking longer to plan and implement than had been initially anticipated by Bell Canada.
2. It would appear from what you indicated confidentially in your report that the deferral account funds allocated for the Third-Party App Developer Program won’t be fully utilized until the end of ####, which would be inconsistent with the Commission’s determination in Telecom Decision 2015-563 which stipulates at paragraph 18 that the deferral account funds allocated for this initiative are to be fully utilized by the end of 2019.
   1. Please explain why the deferral account funds allocated for this initiative cannot be fully utilized by 31 December 2019. If the funds are not utilized by that date, how you will ensure that they are no later than the end of ####.
   2. Please explain how extending the Third-Party App Developer Program to #### will be beneficial to Canadians with a disability as intended in Telecom Decision 2015-563.
3. Confirm that Bell Canada will offer at least one third-party accessibility app by the end of 2019.
4. Explain how Bell Canada’s program as described in its 2019 Annual Status Report meets the objective of a Third-Party App Developer Program that “[…] include[s] activities that would proactively engage third-party developers and increase their awareness of the interfaces available for accessibility development on the smartphones offered by the Bell companies” ^Footnote4 as determined in Telecom Decision 2015-563. Include the following information in your answer:
   • the number and type of accessibility contests and prizes;
   • the number and type of accessibility hackathons;
   • the number and type of accessibility partnerships;
   • the number and type of accessibility events; and
   • the communications plan and strategy developed to proactively promote the events and engage third party developers.

Procedures for filing

Response to this requests for information must 1) refer to the file number noted above, and 2) be sent to the Secretary General of the Commission via My CRTC Account (at the following link: https://crtc.gc.ca/eng/cover.htm) using GCKey. GCKey allows you to securely access the Government of Canada’s online services and conduct online business.

For further information on how to submit your response, see the CRTC’s web page Submitting applications and other documents to the CRTC using My CRTC Account.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277. As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, parties may designate certain information as confidential. Parties must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

Should you have any questions, please contact Natalie Riendeau, Senior Policy Analyst, Social and Consumer Policy, at natalie.riendeau@crtc.gc.ca.

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

Yours sincerely,

(Original signed by)

Nanao Kachi
Director, Social and Consumer Policy
CRTC

Date modified:

2019-05-22