Telecom & Broadcasting Commission Letter addressed to Distribution List
Ottawa, 14 May 2020
Our reference: 1011-NOC2020-0124
Subject: Call for comments – Regulations to be made under the Accessible Canada Act, Telecom and Broadcasting Notice of Consultation CRTC 2020-124, as amended – Proposal regarding deferral account funds
Dear Mesdames, Sirs,
Commission staff is in receipt of a letter from Bell Canada dated 12 May 2020, filed on the record of the proceeding initiated by Telecom and Broadcasting Notice of Consultation CRTC 2020-124 (the Notice). In the Notice, the Commission seeks comments on the structure and content of regulations that will establish the manner and form of the reporting obligations set out in the Accessible Canada Act (ACA).
In its letter, Bell Canada notes that it has $125,000 remaining in its deferral accountFootnote1 and proposes that the Commission approve the distribution of these funds to defray the costs of public interest and accessibility intervener participation in the proceedings to make regulations under the ACA. As described by the Commission in the Notice, this includes the present proceeding and a follow-up proceeding in which the draft regulations are to be published for comment.
As certain interveners have indicated, encouraging broad participation in ACA proceedings is a laudable goal and the importance of including persons with disabilities in the development of regulations under the ACA has been incorporated into the principles of the Act itself. However, the ACA does not contain a mechanism by which the Commission may award costs to participants in proceedings under the ACA, in contrast to the Telecommunications Act, which does contain such a mechanism.
Under Bell Canada’s proposal, the Commission would be responsible for determining eligibility and for fixing the amounts of the available funds to be distributed to parties, in the same manner it makes telecom costs awards. The Commission would then order Bell Canada to pay out funds accordingly.
Commissions staff considers that this is an innovative proposal that, on its face, has merit and is worth pursuing.
In staff’s view, using Bell Canada’s remaining deferral account funds in the manner proposed would contribute to improving accessibility, including for customers of telecom services, and would be consistent with prior Commission determinations regarding the use of deferral account funds for accessibility initiatives.Footnote2
Using the funds in this way would assist the Commission in gathering a comprehensive record upon which it can ultimately decide how to operationalize the reporting requirements imposed on regulated entities – including Canadian carriers and Telecommunication Service Providers – under the ACA.
In light of all of the above, staff generally supports this proposal and intends to bring it before the Commission in an expedited fashion for approval and further specific direction regarding implementation.
If you have any questions regarding the contents of this letter, please do not hesitate to contact Nanao Kachi, Director, Social and Consumer Policy at 819-997-4700 or firstname.lastname@example.org.
[original signed by]
Senior General Counsel
Ms. Lisa Anderson
Deaf Wireless Canada Consultative Committee
Ms. Monica Auer
Forum for Research and Policy in Communications
Mr. Wissam Constantin
Canadian Association of the Deaf-Association des Sourds du Canada
Mr. Jonathan Daniels
Mr. Lui Greco
Mr. John Lawford
Public Interest Advocacy Centre
Ms. Megan McHugh
Canadian National Society of the Deaf-Blind
Mr. Elliott Richman
Deafness Advocacy Association Nova Scotia
Mr. Anthony Tibbs
Media Access Canada
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