Telecom - Staff Letter addressed to the Distribution List

Ottawa, 26 April 2024

Reference(s): 1011-NOC2020-0178

BY EMAIL

Distribution List

Subject: Accessible mobile wireless service plans (2023-41) – 2024 Reports

In Mobile wireless service plans that meet the needs of Canadians with various disabilities (Telecom Regulatory Policy CRTC 2023-41, thereafter the Policy), the Commission imposed new requirements on all wireless service providers (WSPs) to improve the accessibility of wireless plans (accessible plans). This includes annual reporting requirements regarding their accessible plans and their ongoing consultations with persons with disabilities.

While the 2023 reports were more limited in scope in recognition of the limited time from the publication of the policy to the date on which the reports were due, the 2024 reports must address all subjects raised in the Policy, including those noted at paragraphs 141-142.

The appendix of this letter sets out a reminder of the questions that all WSPs must answer when submitting their 2024 Accessible Wireless Reports. Companies that operate flanker brands must file responses on behalf of these brands in addition to their primary brands.

Your response must be filed no later than 1 June 2024.

Procedures for filing

As set out in section 39 of the Telecommunications Act (the Act) and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Procedures for filing confidential information and requesting its disclosure in Commission proceedings, WSPs may designate certain information as confidential. A WSP designating information as confidential must provide a detailed explanation on why the relevant information qualifies for designation as 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.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

The reports will be available on the public file.

Yours sincerely,

Nanao Kachi
Director, Social and Consumer Policy

Distribution List

bell.regulatory@bell.ca
geoff@brooketel.ca
Regulatory@brucetelecom.com
tomsullivan@brucetelecom.com
Regulatory.Matters@corp.eastlink.ca
regulatory@corporate.wightman.ca
martha.facey@execulink.com
a.lawrence@hay.net
ryan.mcclinchey@hurontel.on.ca
regulatory@icewireless.com
regulatory@iristel.com
knaylor@mornington.ca
lhallahan@mornington.ca
regulatory@quadro.net
regaffairs@quebecor.com
melanie.cardin@quebecor.com
dennis.beland@quebecor.com
rwi_gr@rci.rogers.com
document.control@sasktel.com
richard.biron@sogetel.com
stephen.scofich@tbaytel.com
regulatory@tccmail.ca
reglementa@telebec.com
regulatory.affairs@telus.com
harleen.sawhney@zoomermedia.ca
scott_laird@ztarmobile.com

Appendix – Questions for all WSPs

Question 1. Composition of accessible plans 

Please detail:

  1. the various types of accessible plans that you made available in the market in the course of the past year, and
  2. any accessible plans that have been withdrawn from the market during that period and the reason for doing so.

As per the Policy, “accessible plans” includes any accessibility-specific plans, rebates, and/or add-ons.

Question 2. Total number of subscribers to accessible plans

Please provide the number of subscribers to the above noted accessible plans as of the date of your response.

In the interest of transparency and given the nature of this market, Commission staff asks each WSP to disclose publicly, at a minimum, the aggregated total of subscribers to their accessible plans.

Question 3. Consultations with persons with disabilities

Please detail any consultations that were held with persons with disabilities in the past year, including who from the disability community took part in the consultations, and any insights that were gained.

Further detail changes you put in place as a result of these consultations to further the objectives of the Policy beyond those addressed in other questions of this report.

Question 4. Promotion and awareness of accessible wireless plans

Please detail the efforts undertaken to ensure that persons with disabilities are aware of the existence of accessible wireless plans and how your consultations with persons with disabilities informed these efforts.

Specifically, address any promotion and training efforts you have undertaken, how you measure the success of those initiatives, and any planned adjustments to your approach going forward.

Question 5. Verifying eligibility

Please report on your current approach to verifying eligibility and how it may have changed following consultations with persons with disabilities. Detail whether that approach ensures that persons with disabilities can easily access plans that suit their needs.

Question 6. Transferable record of eligibility

In the Policy, the Commission encouraged the telecommunications industry to establish a common transferable record of eligibility for persons with disabilities (an “accessibility passport”), noting that “this would improve both accessibility and competition by making switching WSPs easier for persons with disabilities, while also enhancing privacy because prospective service providers would not need to know a customer’s specific situation, only that they are eligible.”

Please detail the efforts undertaken towards a common transferable record of eligibility.

Question 7. Unfettered access to the VRS

Please detail the measures undertaken to address the unreasonable disadvantage identified under subsection 27(2) of the Act with respect to unfettered access to VRS in paragraphs 90 to 95 the Policy.

Question 8. Unlimited accessible plans

Please detail your progress regarding unlimited accessible plans, specifically how you are using zero-rating and traffic management practices with the available accessible plans, and how these practices are being used to promote, rather than restrict, accessibility of wireless services for persons with disabilities in accordance with paragraphs 100 to 109 of the Policy.

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