Telecom Regulatory Policy CRTC 2009-183
Route reference: Telecom Public Notice 2008-15
Ottawa, 8 April 2009
Regulatory requirements pertaining to the monitoring and reporting of certain data
File number: 8663-C12-200814279
In this decision, the Commission eliminates or modifies eight of the nine regulatory measures under review regarding monitoring and reporting requirements for certain telecommunications services.
1. In Telecom Decision 2007-51, the Commission released an action plan for reviewing existing regulatory measures in light of the Governor in Council's Order Issuing a Direction to the CRTC on Implementing the Canadian Telecommunications Policy Objectives, P.C. 2006-1534, 14 December 2006 (the Policy Direction). As part of the action plan, the Commission identified obligations to track and report data to the Commission as a matter to be reviewed.
2. In Telecom Public Notice 2008-15, the Commission invited parties to comment on the continued appropriateness of four monitoring and reporting requirements,1 as well as on the monitoring and reporting of any additional matters except those pertaining to the collection of data associated with telecommunications fees, the Commission's annual monitoring report, and quality of service results.2
3. The Commission received submissions from Bell Aliant Regional Communications, Limited Partnership, Bell Canada, Saskatchewan Telecommunications, and Télébec, Limited Partnership (collectively, Bell Canada et al.); the Coalition of Communications Consumers (the Coalition); the Public Interest Advocacy Centre on behalf of the Consumers' Association of Canada and the National Anti-Poverty Organization (collectively, PIAC); Rogers Cable Communications Inc. (RCCI); and TELUS Communications Company (TCC).
4. The public record of this proceeding, which closed on 11 December 2008, is available on the Commission's website at www.crtc.gc.ca under ''Public Proceedings'' or by using the file number provided above.
The issues to be reviewed
5. The Commission will review nine monitoring and reporting requirements identified by the Commission and parties in this proceeding in order to determine whether they continue to be appropriate in light of the Policy Direction.3
6. For each requirement, the Commission will first assess whether the regulatory measure remains relevant and, if so, whether the Commission can rely on market forces to achieve the purpose underlying that regulatory measure. An identification of the telecommunications policy objectives (the policy objectives) of the Telecommunications Act (the Act) that are relevant to the purpose of the requirement accompanies this review as required.
7. If the Commission determines that the intended purpose of the regulatory measure continues to be relevant but market forces cannot be relied on to achieve the underlying purpose, it will then address the following, as required, for each monitoring and reporting requirement:
- Is it efficient and proportionate to its purpose?
- Does it interfere with the operation of competitive market forces to the minimum extent necessary to meet the policy objectives?
- Is it symmetrical and competitively neutral?
8. Details regarding the Commission's determinations on each of the monitoring and reporting requirements are set out in subsequent sections of this decision. The Commission's determinations in this decision result in the elimination, retention, or modification of the monitoring and reporting requirement in question.
9. Finally, the Commission addresses other matters raised by some parties in this proceeding.
10. The monitoring and reporting requirements related to affordability were first set out in Telecom Decision 96-10. The Commission modified the requirements in a number of subsequent determinations, including Telecom Order 97-1214, Order 2000-393, and Telecom Decision 2004-73.
11. The incumbent local exchange carriers (ILECs)4 are currently required to file a single annual affordability report (the affordability report) with the Commission that includes, among other things, analysis of the following:
- affordability, telephone/voice communication penetration rates, and reasons for non-subscription, based on results reported in Statistics Canada's annual Survey of Household Spending (SHS) and Residential Telephone Service Survey (RTSS);
- relevant disconnection statistics, categorized by reasons why the service has been disconnected; and
- take rates for bill management options.
12. PIAC submitted that the purpose of the affordability report is linked to the objective set out in paragraph 7(b)5 of the Act. The Coalition submitted that by relying on this regulation, the Commission is able to advance the policy objective set out in paragraph 7(h)6 of the Act. RCCI submitted that reporting affordability information is very useful to the Commission in ensuring that its regulatory objectives are met.
13. PIAC also submitted that the benefits of the current affordability report are that consumer groups, as well as policymakers and telecommunications service providers (TSPs), have real information on the affordability of basic telephone service, which remains a necessary lifeline to society. However, PIAC submitted that gathering and reporting useless information does not advance the goal of affordability. It suggested that a change to what is monitored and reported, rather than a wholesale abandonment, is required to meet the objective of affordability found in the Act.
14. Bell Canada et al. submitted that the costs of producing the report exceed its value and that its benefits are unclear. They submitted, therefore, that the affordability monitoring and reporting requirements should be eliminated.
15. TCC submitted that although affordability is one of the objectives under the Act, monitoring and reporting on affordability does not necessarily advance that specific policy objective. TCC also submitted that Statistics Canada already conducts annual studies examining the overall affordability of residential telephone services and suggested that any additional data currently reported to the Commission is of limited value.
16. The Commission notes that the affordability report was established so that the Commission could detect the development and specific nature of any affordability concerns, and so that it could take the appropriate action if and when it becomes necessary to do so.
17. The Commission notes that, currently, only the ILECs are required file the affordability report. The Commission also notes that an important part of the information presented in the affordability report is available in Statistics Canada's RTSS and SHS.
18. The Commission considers that eliminating the affordability report would not prevent it from monitoring the affordability of local service rates. The Commission can continue to use data from other sources, such as the Statistics Canada surveys, and can request additional data from TSPs to address specific concerns, as required.
19. Accordingly, the Commission eliminates the regulatory requirement for ILECs to file the affordability report. The Commission will request information from TSPs as required in order to gather data related to affordability.
II. Local pay telephone competition
20. The monitoring and reporting requirements related to local pay telephone competition were first set out in Telecom Decision 98-8 coincident with the introduction of competition in that market. The Commission modified the requirements in Telecom Decision 2004-47. The ILECs are currently required to file with the Commission annual reports that provide details about pay telephone installations, and about pay telephone removals and the reasons for removal.7
21. PIAC submitted that paragraph 7(c)8 of the Act explicitly acknowledges competition as a policy objective. It also submitted that pay telephone service remains an important lifeline for low income and vulnerable consumers and it repeated its arguments about affordability in relation to pay telephone monitoring and reporting requirements.
22. The Coalition submitted that the purpose of the local pay telephone reports is linked to the objectives set out in paragraphs 7(a),9 7(b), and 7(h) of the Act. The Coalition further submitted that many lower income Canadians still use local pay telephones, many Canadians still do not take advantage of wireless services, and the Commission's regulatory oversight is still required to ensure that local pay telephone services remain reasonably available and accessible.
23. Bell Canada et al. submitted that given that the Commission has established certain notification requirements for areas where the last pay telephone in a community is scheduled for removal,10 it is unclear what purpose the annual reports serve. Similarly, TCC submitted that the notification and consultation process requirements associated with the removal of the last pay telephone in a wire centre already provide sufficient safeguards to deal with any concerns regarding removal of pay telephones.
24. The Commission notes that the local pay telephone report was established in order to enable the Commission to monitor the impact of competition on the pay telephone market. The Commission also notes that only the ILECs are required to file annual reports with details related to pay telephone installations and removals.
25. The Commission considers that eliminating the annual pay telephone report would not prevent it from monitoring the impact of pay telephone competition. The Commission expects that TSPs will maintain records of pay telephone installations and removals, and notes that it can request such information from TSPs, as required.
26. Accordingly, the Commission eliminates the regulatory requirement for ILECs to file annual local pay telephone reports. The Commission will request information from TSPs as required in order to gather data related to pay telephone installations and removals.
III. Modem hijacking
27. The monitoring and reporting requirements related to modem hijacking were set out in Telecom Decision 2005-13. In that decision, the Commission stated that it expected the ILECs to track complaints regarding modem hijacking and to make them available to the Commission upon request.11
28. Parties who commented on this matter were of the view that the requirement related to modem hijacking is no longer necessary.
29. The Coalition and TCC submitted that the technological shift and movement of customers from dial-up to high-speed Internet connections has reduced the potential for modem hijacking. TCC noted that there had been a sharp decline in the number of complaints about modem hijacking since Telecom Decision 2005-13 was issued and that no complaints had been received since 2006.
30. The Commission considers that the current regulatory measure is no longer relevant. Accordingly, the Commission eliminates the regulatory requirement for ILECs to track and report complaints regarding modem hijacking.
IV. Manual access to the 9-1-1 Automatic Location Identification database
31. The reporting requirements related to manual access to the 9-1-1 Automatic Location Identification (ALI) database were first set out in Telecom Decision 99-17. The Commission modified those requirements in Telecom Circular 2005-5. The ILECs are currently required to file with the Commission annual reports listing all manual access requests made to the 9-1-1 ALI database by public safety answering points (PSAPs).12
32. Parties who commented on this matter were of the view that the reporting requirement related to manual access to the 9-1-1 ALI database is no longer necessary.
33. Bell Canada et al. and TCC submitted that any abuse of manual access to the 9-1-1 ALI database by the PSAPs would be detected by the ILEC in question and addressed expeditiously, regardless of the existence of a report. They also submitted that the various other safeguards contained in their 9-1-1 agreements that were implemented pursuant to Telecom Decision 99-1713 offer sufficient protection and means of addressing any such abuse.
34. The Coalition submitted that the reporting requirement related to manual access to the 9-1-1 ALI database serves no useful purpose since no concerns about inappropriate disclosure of confidential customer information have materialized to date.
35. The Commission agrees with parties that the regulatory measure is no longer relevant and that the reporting requirements related to manual access to the 9-1-1 ALI database can be eliminated.
36. Accordingly, the Commission eliminates the regulatory requirement for ILECs to file annual reports listing all manual access requests made to the 9-1-1 ALI database by the PSAPs.
V. Competitor service interruption
37. The reporting and monitoring requirements related to competitor service interruption were first set out by the Commission in Order 2000-397. The Commission modified the requirements in Telecom Circular 2005-5. ILECs are currently required to file with the Commission annual reports listing all service outages that affect competitors and that exceed 15 minutes in duration, along with other information for each reportable outage.14
38. Bell Canada et al. submitted that the competitor service interruption report is redundant due to competitor quality of service reporting requirements.
39. TCC submitted that because network outages generally affect both an ILEC's retail and wholesale customers, an ILEC normally cannot benefit when an outage causes its competitors' networks to be adversely affected. In TCC's view, the current reporting requirement is neither efficient nor proportionate to the purpose of detecting anti-competitive conduct.
40. The Commission notes that no party objected to the elimination of this reporting requirement. The Commission also notes that the type of disputes that led to the initial requirement have not occurred since 2000.
41. Accordingly, the Commission eliminates the regulatory requirement for ILECs to file annual reports related to competitor service interruption.
VI. 4-1-1 directory assistance call volume
42. In a letter dated 11 May 2007, the Commission required Bell Canada to submit semi-annual reports indicating the year-over-year changes in monthly 4-1-1 call volume. This requirement was established to monitor the impact of Bell Canada's modified distribution policy for residential telephone directories on 4-1-1 call volume after the company moved from annual to biennial distribution.
43. Bell Canada et al. submitted that all affected markets have now experienced at least one directory cycle since the change in distribution frequency. Bell Canada et al. were of the view that given the continuing decline in 4-1-1 call volume and the absence of customer complaints regarding Bell Canada's initiative, continued reporting of 4-1-1 call volume is unnecessary.
44. The Commission notes that no party objected to the elimination of the monitoring and reporting requirements related to 4-1-1 call volume. The Commission also notes that based on the information provided by Bell Canada, there has been a decline in 4-1-1 call volume since the change in distribution frequency.
45. Accordingly, the Commission eliminates the regulatory requirement for Bell Canada to file semi-annual 4-1-1 call volume reports.
VII. Competitive interexchange private line routes
46. The reporting requirement related to competitive interexchange private line (IXPL) routes was set out in Telecom Order 99-434. Competitors of the major ILECs are currently required to file with the Commission reports identifying all IXPL routes for which they provide or offer IXPL service that meet the criterion established in Telecom Order 99-434. The information must be filed twice a year, on 1 April and 1 October. Upon receipt of these reports, the Commission issues a decision granting forbearance to the appropriate ILECs for the routes in question.
47. RCCI requested that the IXPL reports be reduced to a single filing per year, to be filed coincident with the Commission's other annual data collection activities. RCCI submitted that, based on its experience to date, very few IXPL forbearance applications are filed each year. It submitted that reducing the reporting to annually would be consistent with the requirement in the Policy Direction that regulation should be efficient and proportionate to its purpose. RCCI also submitted that filing twice per year imposes unnecessary costs on service providers without any obvious additional benefits, while a single filing each year would be sufficient to enable the Commission to assess the competitiveness of the market for any applications received.
48. Bell Canada et al. noted that the Commission had forborne from regulating 321 IXPL routes in Telecom Decisions 2008-44 and 2008-111, pursuant to forbearance applications based on the 2008 IXPL reports. Given the importance of these reports to the forbearance process for IXPL routes, Bell Canada et al. submitted that they did not believe that it would be appropriate to modify or eliminate the reports unless all IXPL routes are forborne from regulation. Bell Canada et al. also suggested that given the limited number of IXPL routes that have yet to be forborne from regulation, it would be appropriate for the Commission to grant forbearance for those routes.
49. TCC submitted that the Commission should maintain the current reporting frequency of twice a year because it strikes a good balance between the costs associated with the reporting requirement and the benefit of having competitive information regarding IXPL routes available in a reasonable time frame. TCC also submitted that, in light of the benefit, the requirement for competitors to file their current IXPL route reports twice a year continues to be a measure that is efficient and proportionate to its purpose, thus making the reporting requirement compliant with the Policy Direction.
50. The Commission considers that Bell Canada et al.'s suggestion regarding forbearance for the remaining IXPL routes is beyond the scope of this proceeding.
51. The Commission notes that the parties that commented on this measure agree that this requirement is relevant to its purpose.
52. The Commission is not convinced by RCCI's argument in favour of reducing the frequency of the IXPL reports. While the Commission recognizes that service providers incur some additional costs in compiling the required information and submitting it to the Commission twice a year rather than once, the Commission considers that the benefit of granting forbearance for these routes within a reasonable time period outweighs the costs. The Commission also considers that the current reporting requirement is consistent with the Policy Direction because it is efficient and proportionate to its purpose, and is minimally intrusive.
53. Accordingly, the Commission maintains the competitive IXPL reporting requirements established in Telecom Order 99-434.
VIII. Telemarketing complaints
54. The monitoring and reporting requirements related to telemarketing complaints were first set out in Telecom Decision 2004-35 in order to identify telemarketing policies that might require modification. The Commission modified these requirements in Telecom Decisions 2004-63 and 2007-48.
55. TSPs are currently required to file with the Commission semi-annual reports summarizing telemarketing complaint statistics separately for a) complaints from business consumers and b) complaints from residential consumers.15 TSPs must file these reports until six months after the launch of the National Do Not Call List (DNCL). The National DNCL began operating on 30 September 2008.
56. RCCI submitted that the objective of the monitoring and reporting requirements established in Telecom Decision 2004-35 was to enable the Commission to gather useful information to design a telemarketing regulatory regime. However, RCCI submitted that there is no longer a need for TSPs to file telemarketing reports because this information is filed directly with the DNCL operator. In RCCI's view, requiring additional filings is inconsistent with the Policy Direction because they are unnecessarily duplicative, inefficient, and costly.
57. Bell Canada et al. agreed with RCCI that maintaining the requirement to report telemarketing complaints statistics is unnecessarily duplicative, inefficient, and costly. Similarly, PIAC submitted that these reports could be considered duplicative and the Commission could therefore eliminate them.
58. The Commission notes that telemarketing complaints are now filed with the National DNCL operator and forwarded to the Commission for investigation. Therefore, semi-annual telemarketing reports are no longer required.
59. Accordingly, the Commission eliminates the regulatory requirement for TSPs to file semi-annual reports on telemarketing complaints.
IX. Affidavits for competitor digital network services
60. In Telecom Decision 2002-34, the Commission prohibited simple resale of competitor digital network (CDN) services. In Telecom Decision 2005-6, the Commission determined that the chief executive officer (CEO) of each competitor that subscribes to an ILEC's CDN services must file an affidavit annually to confirm compliance with that prohibition and to attest that the route or pathway associated with each leased access facility included as part of the CDN services ultimately connects at a point of presence.16
61. TCC suggested that the process could be improved by authorizing an officer of the company to sign the affidavit confirming compliance, in lieu of the CEO. TCC submitted that a one-time attestation would serve the purpose, thus further improving the process and making this regulatory requirement more efficient.
62. Bell Canada et al. proposed that this measure be modified so that the person signing the affidavit could be the CEO, or an officer or a vice-president responsible for the network operations of the competitor.
63. RCCI supported TCC's view that a one-time attestation should be sufficient. It agreed with Bell Canada et al. that an officer or a vice-president responsible for the network operations should have the authority to sign the affidavit, but requested that any executive – including regulatory and legal executives – with knowledge of the facts to be sworn to should also be able to sign the one-time attestation.
64. The Commission notes that the parties that commented on this measure agree that this regulatory measure is relevant to its purpose.
65. The Commission considers that the person signing the affidavits must be aware of the implications related to the requirements. The Commission considers that either a senior management officer of the company or a vice-president with responsibilities related to network operations, or an executive in legal or regulatory affairs, should have the authority to sign the affidavit as well as the CEO.
66. The Commission also considers that a one-time attestation by a competitor to confirm its current and future compliance with the Commission's determinations in Telecom Decisions 2006-1, 2005-6, and 2002-34 would be appropriate.
67. Accordingly, the Commission modifies this regulatory measure so that either the CEO, a senior management officer of the company or a vice-president with responsibilities related to network operations, or an executive in legal or regulatory affairs of each competitor that uses an ILEC's CDN services must sign and file an affidavit with the Commission.
68. The Commission also determines that a one-time attestation is sufficient. As such, the Commission directs each competitor that uses an ILEC's CDN services to file an affidavit attesting to its current and future compliance with the Commission's determinations by the end of their current annual filing cycle.
69. TCC identified a number of other reports that it submitted should be reviewed by the Commission in light of the Policy Direction, specifically the following: quality of service reports, monitoring and reporting pertaining to the collection of data for telecom fees, contribution revenue filing reports, Canadian telecom service revenues reports, and the annual ownership report. Bell Canada et al. and TCC submitted that the monitoring report should also be reviewed.
70. The Commission notes that some of these initiatives or reports are beyond the scope of this proceeding. For the others identified by TCC, the Commission considers that there is insufficient information on the record of the proceeding for the Commission to review these initiatives or reports.
- Revised regulatory requirements to provide information to customers, Telecom Regulatory Policy CRTC 2009-156, 24 March 2009
- Forbearance from the regulation of high capacity/digital data services interexchange private line services on certain additional routes, Telecom Decision CRTC 2008-111, 26 November 2008, as amended by Telecom Decision CRTC 2008-111-1, 16 December 2008
- Review of the regulatory requirements pertaining to the monitoring and reporting of certain data, Telecom Public Notice CRTC 2008-15, 27 October 2008
- Forbearance from the regulation of high capacity/digital data services interexchange private line services on certain additional routes, Telecom Decision CRTC 2008-44, 29 May 2008, as amended by Telecom Decision CRTC 2008-44-1, 19 June 2008
- Action plan for the review of Commission regulatory measures in light of Order in Council P.C. 2006-1534, Telecom Decision CRTC 2007-51, 11 July 2007
- Unsolicited Telecommunications Rules framework and the National Do Not Call List, Telecom Decision CRTC 2007-48, 3 July 2007, as amended by Telecom Decision CRTC 2007-48-1, 19 July 2007
- Price cap framework for large incumbent local exchange carriers, Telecom Decision CRTC 2007-27, 30 April 2007
- Part VII application to revise the Telecommunication Fees Regulation, 1995, Telecom Decision CRTC 2006-71, 6 November 2006
- Forbearance from the regulation of retail local exchange services, Telecom Decision CRTC 2006-15, 6 April 2006, as amended by Order in Council P.C. 2007-532, 4 April 2007
- TELUS Communications Inc. - Application with respect to Telecom Decision CRTC 2005-6 - Location of competitor point of presence, Telecom Decision CRTC 2006-1, 6 January 2006
- Union des consommateurs, Public Interest Advocacy Centre and Option Consommateurs – Automatic dialers and modem hijacking, Telecom Decision CRTC 2005-13, 9 March 2005
- Competitor Digital Network Services, Telecom Decision CRTC 2005-6, 3 February 2005, as amended by Telecom Decision CRTC 2005-6-1, 28 April 2006
- Filing of reports on 9-1-1 manual access to the ALI database and on incumbents' service interruptions to competitors, Telecom Circular CRTC 2005-5, 4 April 2005
- Modification to the affordability monitoring program for residential telephone service in Canada, Telecom Decision CRTC 2004-73, 9 November 2004
- Application by the Canadian Marketing Association to stay Decision 2004-35, Telecom Decision CRTC 2004-63, 28 September 2004
- Access to pay telephone service, Telecom Decision CRTC 2004-47, 15 July 2004
- Review of telemarketing rules, Telecom Decision CRTC 2004-35, 21 May 2004
- Regulatory framework for second price cap period, Telecom Decision CRTC 2002-34, 30 May 2002, as amended by Telecom Decision CRTC 2002-34-1, 15 July 2002
- Altering terms of service for competitors that are customers, Order CRTC 2000-397, 12 May 2000
- Commission modifies reporting requirements for affordability, Order CRTC 2000-393, 10 May 2000
- 9-1-1 Service - Rates for Wireless Service Providers, Centrex Customers and Multi-Line Customers/Manual Access to the Automatic Location Identification Database, Telecom Decision CRTC 99-17, 29 October 1999
- Follow-up Proceeding to Telecom Decision CRTC 97-20: Establishment of criterion and process for considering further forbearance for High Capacity/DDS interexchange private line services, Telecom Order CRTC 99-434, 12 May 1999
- Local pay telephone competition, Telecom Decision CRTC 98-8, 30 June 1998
- Telecom Order CRTC 97-1214, 29 August 1997
- Local service pricing options, Telecom Decision CRTC 96-10, 15 November 1996, as amended by Telecom Decision CRTC 96-10-1, 29 November 1996
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 These requirements related to affordability, local pay telephone competition, modem hijacking, and manual access to the 9-1-1 Automatic Location Identification database.
 Parties identified additional monitoring and reporting requirements for review related to competitor service interruption, 4‑1‑1 call volume, competitive interexchange private line routes, telemarketing complaints, and affidavits for competitor digital network services.
 Any monitoring and reporting requirement not examined in this decision remains in effect.
 The ILECS that are required to file the affordability report are: Bell Aliant Regional Communications, Limited Partnership; Bell Canada; MTS Allstream Inc.; Northwestel Inc.; and TCC.
 Paragraph 7(b) of the Act states the following objective: "to render reliable and affordable telecommunications services of high quality accessible to Canadians in both urban and rural areas in all regions of Canada."
 Paragraph 7(h) of the Act states the following objective: "to respond to the economic and social requirements of users of telecommunications services."
 The reports also include the name of the city or town, the civic address, the name of the building (if applicable), and the number of pay telephones remaining at the premises.
 Paragraph 7(c) of the Act states the following objective: "to enhance the efficiency and competitiveness, at the national and international levels, of Canadian telecommunications."
 Paragraph 7(a) of the Act states the following objective: "to facilitate the orderly development throughout Canada of a telecommunications system that serves to safeguard, enrich and strengthen the social and economic fabric of Canada and its regions."
 See Telecom Decision 2004-47 and Telecom Regulatory Policy 2009-156. Where the last pay telephone in a community is scheduled for removal, ILECs must provide a 60‑day notification period to the location provider and the local government, post a notice on the pay telephone, and place a notice in the local newspaper at least 60 days prior to removal.
 Modem hijacking occurs when software containing an automatic dialer is downloaded, sometimes without the subscriber's knowledge, onto the subscriber's computer through his or her Internet connection. The dialer then connects the subscriber's computer to a website through the subscriber's modem without his or her involvement, triggering long-distance charges.
 The ILECs are also required to ensure that the information on manual access requests made to the ALI database remains readily available in order to provide PSAP reports if and when requested by the Commission.
 In Telecom Decision 99-17 the Commission directed the ILECs to amend their 9-1-1 agreements to include, among other things, terms and conditions related to disclosure of confidential information, circumstances when manual access to the 9-1-1 ALI database can be performed and by whom, the requirement for a PSAP operator to record details associated with each request, restrictions on the use of any information obtained through a manual request, and suspension of data links in the event of a breach.
 This information includes the time and location of the outage, the competitor(s) affected by the outage, the duration and reason for the outage, the extent to which the outage affected service to the telephone company's other customers, the time at which service was restored to the competitor(s) affected by the outage, and the time at which service was restored to the telephone company's other customers.
 These reports are to include, among other things, the following information: the total number of telecommunications complaints, the total number of unsolicited telecommunications complaints, the number of complaints where none of the Unsolicited Telecommunications Rules were breached, the number of out-of-territory complaints when service is provided to the telemarketer by another TSP, and the number of complaints related to telemarketing based on personal referrals.
 The requirements were modified in Telecom Decision 2006-1, in which the Commission clarified that CDN services must ultimately connect at a point of presence in Canada.
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