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Telecom - Commission letter addressed to the Distribution List

Ottawa, 2 August 2021

Our reference: 1011-NOC2020-0178

BY EMAIL

To: Distribution List

Subject: Procedural letter – Telecom Notice of Consultation CRTC 2020-178 – Call for comments – Accessibility – Mobile wireless service plans that meet the needs of Canadians with various disabilities –Request for information from wireless service providers

Dear Madam/Sir:

This letter sets out questions for all wireless service providers in relation to Telecom Notice of Consultation CRTC 2020-178, particularly requests for updated information about the offering and promotion of mobile wireless service packages that meet the needs of Canadians with disabilities.

Responses to these questions are required no later than 17 August 2021.

See the appendix attached for the list of questions. 

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Sincerely,

Nanao Kachi
Director, Social and Consumer Policy
CRTC

Distribution list
regulatory@deafwireless.ca
wissam@cad.ca
ffolino@cad.ca
mchugh.mm@gmail.com
myles.murphy@nf.sympatico.ca
dprongfa@gmail.com
daans@ns.sympatico.ca
jroots@cad.ca
bell.regulatory@bell.ca
brooke@brooketel.coop
regulatory@brucetelecom.com
regulatory.matters@corp.eastlink.ca
martha.facey@execulinktelecom.ca
a.lawrence@hay.net
ryan.mcclinchey@hurontel.on.ca
regulatory@icewireless.com
knaylor@mornington.ca
scott_laird@ztarmobile.com
regulatory@quadro.net
regulatory@rci.rogers.com
document.control@sasktel.com
regulatory@sjrb.ca
richard.biron@sogetel.com
stephen.scofich@tbaytel.com
regulatory.affairs@telus.com
tcc@tcc.on.ca
dennis.beland@quebecor.com
carl.macquarrie@corp.xplornet.com
Regulatory@wightman.ca
Charlestoth98@gmail.com
lui.greco@cnib.ca
dbruce@isys.ca
Reachmich@gmail.com
sgualt69@hotmail.com
daniel@falco.ca
gillian@sci-can.ca
lisa@deafwireless.ca
resono@icloud.com
bill@sci-can.ca
vinuac@hotmail.com
terri.nolt@gmail.com
hkray@hotmail.com
chair@deafwireless.ca

Appendix: Request for information from wireless service providers

Questions for all wireless service providers:

  1. Provide an update, if necessary (that is, if there has been a material change in relevant circumstances since responses were filed), to the questions that were originally posed as part of Telecom Notice of Consultation 2020-178, Appendix 1, questions 1-6.

Question for Videotron:

  1. Provide a response on behalf of Fizz, Videotron’s flanker brand, to the questions that were originally posed as part of Telecom Notice of Consultation 2020-178, Appendix 1, questions 1-6.

Question for Bell:

  1. Bell Mobility has resellers for which you manage the cellular network, device hardware, and related services, including wireless plans.  If a customer of one of your resellers has a question about accessible plans, features, or discounts that the reseller’s sales or customer service representatives cannot answer, can they seek further information and support from Bell under your reseller agreement?  For example, can resellers seek support from Bell’s Accessibility Service Centre?

Questions for Brooke Telecom, Bruce Telecom, Hay Communications, Huron Telecommunications, Mornington Communications, Quadro Communications, Sogetel Mobilité, and Tuckersmith Communications (Bell Mobility resellers):

  1. As Bell Mobility resellers, you have an agreement with Bell Mobility to manage the cellular network, device hardware, and related services, including wireless plans.  If a customer has a question about accessible plans, features, or discounts that your sales or customer service representatives cannot answer, can you seek further information and support from Bell under your reseller agreement?  For example, can you seek support from Bell’s Accessibility Service Centre?
  2. In Telecom Regulatory Policy (TRP) 2016-496, the Commission directed all WSPs to offer mobile wireless service packages that meet the needs of Canadians with disabilities and to publicize all of their disability-specific products/services on their websites, and that these packages must be based on consultations with Canadians with disabilities:

“212. …the Commission directs all WSPs to offer mobile wireless service packages that meet the needs of Canadians with disabilities. These include people who are Deaf or hard of hearing, and primarily use video to communicate, as well as people with visual disabilities who use way-finding and Global Positioning System (GPS) apps. WSPs must make these packages available no later than six months from the date of this decision. These packages must include access to 9-1-1 service and be based on consultations with Canadians with disabilities…”

“214. …the Commission directs all WSPs to publicize all of their disability-specific products/services on their websites, and expects them to use other methods to publicize this information, such as through call centres, no later than six months from the date of this decision.”  (TRP 2016-496, paragraphs 212 and 214)

  1. Given that you offer Bell Mobility plans, confirm whether you also extend an accessibility discount similar to Bell Mobility’s to your customers with accessibility needs.
  2. If you answered question (a) in the negative, explain why you do not offer such a discount, whether you have plans to extend a similar discount going forward, and how you consider your wireless offerings to be consistent with the direction to all WSPs in TRP 2016-496 to offer mobile wireless service packages, based on consultations with Canadians with disabilities, that meet the needs of Canadians with disabilities.
  3. In your responses to requests for information, you stated that your company does not publicize disability-specific products or services on its website, such as any generally applicable accessibility discounts, nor has it engaged in accessibility consultations.  This could potentially be interpreted to result in non-compliance with your regulatory obligations.  Explain how, and by what date, your company intends to comply with the requirements set out in paragraphs 212 and 214 of TRP 2016-496. 

Questions for Execulink Telecom, Freedom Mobile, Ice Wireless, Petro-Canada Mobility, and Wightman Telecom: 

  1. In Telecom Regulatory Policy (TRP) 2016-496, the Commission directed all WSPs to offer mobile wireless service packages that meet the needs of Canadians with disabilities and to publicize all of their disability-specific products/services on their websites, and that these packages must be based on consultations with Canadians with disabilities:

“212. …the Commission directs all WSPs to offer mobile wireless service packages that meet the needs of Canadians with disabilities. These include people who are Deaf or hard of hearing, and primarily use video to communicate, as well as people with visual disabilities who use way-finding and Global Positioning System (GPS) apps. WSPs must make these packages available no later than six months from the date of this decision. These packages must include access to 9-1-1 service and be based on consultations with Canadians with disabilities…”

“214. …the Commission directs all WSPs to publicize all of their disability-specific products/services on their websites, and expects them to use other methods to publicize this information, such as through call centres, no later than six months from the date of this decision.”  (TRP 2016-496, paragraphs 212 and 214)

In your response to a request for information, you stated that your company either:

This could potentially be interpreted to result in non-compliance with your regulatory obligations set out in paragraph 212 and 214 of TRP 2016-496.  Please comment and explain whether, and by what date, your company intends to modify its practices in light of the above. 

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