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Bell Canada 8678-B2-201100594 - Deferral Account Proposal

March 7, 2011
CRTC, Bell Canada
Bell Canada 8678-B2-201100594 - Deferral Account Proposal

Mr. Robert Morin
Secretary General
Ottawa, ON K1A 0N2

Dear Mr. Morin:


I am writing on behalf of the Alliance for Equality of Blind Canadians in connection with Bell Canada's proposal to use deferral account funds to improve the accessibility of Bell's mobile devices and services (the mobility proposal). The AEBC is a national organization of rights holders who are blind, deaf-blind and partially sighted whose work involves improving attitudes and providing input on public policy issues that are of importance to members of our community. As such, Bell Canada's proposal is of considerable interest to our membership.

Representatives of the AEBC met with Mr. Bill Abbott and colleagues on December 10, 2010 to discuss the proposal, and were subsequently provided with a written outline of the proposal for our review. We have received the documents concerning a variety of questions that were posed to Bell, and are pleased to provide our comments.

We believe the involvement of key stakeholders and accessibility experts in the ongoing activities of the mobility proposal will help to ensure that it results in ongoing improvements to accessibility within Bell. This can best be achieved by

a)    Ensuring meaningful involvement of organizations of rights holders like the AEBC, that are made up of persons with disabilities who know best our own needs and aspirations, and who have the right to speak on our behalf; and

b)    By expanding the number of persons with disabilities working for Bell, so that the company develops an increased range of ongoing and internal expertise that will better support ongoing work on accessibility.

The applicant proposes extensive expenditures, including contracting with some external consultants. We believe some funds must be set aside to assist rights holder organizations to provide the level of ongoing input and consultations that are expected during this project. It is not reasonable for Bell to pay external consultants to perform some of the needed work, and expect ongoing free consulting services from the disabled community.

The AEBC believes that all requests for proposals to help with the work outlined in the proposal must not only expect demonstrable knowledge about accessibility for persons with disabilities, but in addition, each bidder should be required to include as part of its team one or more individuals who have a disability, so that some members of the disability community gain employment from these initiatives.

The AEBC believes that the focus on web tools, marketing, life cycle management, procurement, and needs assessment can be useful. We are particularly interested in the applicant's plan to develop a new method for Bell staff to assist customers in determining which products will best meet their needs. This aspect sounds innovative and is designed to improve customer service and customer satisfaction. However, at the same time, we are concerned by the length of time the applicant believes is required to develop and implement this new approach which sounds overly lengthy and costly.

The second part of Bell Canada's proposal, provided in the appendices, contains the detailed estimated costs associated with the introduction of these products and services and is being filed in confidence, pursuant to section 39 of the Telecommunications Act. As a result, the AEBC is unable to comment in detail on this aspect, but we are concerned by both the length of time involved and the amount of funds that will be used internally by the applicant.

In conclusion, the AEBC commends Bell Canada for its proposal, and, at the same time, we wish to remind the applicant that persons with disabilities are customers and, as such, we have the right to expect significant moves towards full access of all telecommunication services and programming. The AEBC looks forward to continuing to collaborate on these and other initiatives that Bell Canada may propose that will expand access to their products and services for Canadians with various disabilities.

Yours truly,


Robin East

Cc       Bill Abbott, Senior Counsel - Regulatory Law, Bell Canada


  • This letter, #2178 was sent March 7, 2011 to CRTC, Bell Canada: Bell Canada 8678-B2-201100594 - Deferral Account Proposal

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