Telecom Commission Letter Addressed to Various parties
Ottawa, 1 November 2017
Our reference: 1011-NOC2017-0033
Ms. Lisa Anderson-Kellett, Chair
Deaf Wireless Canada Consultative Committee
251 Bank Street, Suite 606
Ottawa, Ontario K2P 1X3
Mr. Frank Folino, President
Canadian Association of the Deaf
251 Bank Street, Suite 606
Ottawa, Ontario K2P 1X3
Ms. Megan McHugh, President
Canadian National Society of the Deaf-Blind
405-422 Willowdale Avenue
North York, ON M2N 5B1
Re: Telecom Notice of Consultation CRTC 2017-33, Review of the regulatory framework for text-based message relay services
Dear Ms. Anderson-Kellett, Mr. Folino, and Ms. McHugh:
The present letter is to acknowledge receipt of your letter dated 23 October 2017 in relation to the above-noted proceeding, in which you make two requests, described below.
Request #1 that statistical data numbers from all telecommunications service providers (TSPs) be made available
Your letter requests that “the Commission direct the TSPs [on the distribution list of the Commission staff letter dated 3 February 2017] to submit reports of statistical data numbers for 2015 and 2016 for this proceeding as stated in the Telecom Commission Letter (3 February 2017) in order to produce accurate national totals by 3 November 2017.”
Commission staff notes that the Commission is in receipt of all of the above-noted statistical data numbers from each TSP. However, a subset of that data has been designated as confidential by certain TSPs and is therefore not visible to either you or any other party to this proceeding.
As noted in paragraph 19 of the Notice of Consultation, the CRTC Rules of Practice and Procedure apply to this proceeding and set out, among other things, the procedure for filing confidential information and requesting its disclosure.
Commission staff refers you to paragraphs 24 to 26 of the Guidelines on the CRTC Rules of Practice and Procedure, which explain that:
- a procedural request allows parties to request that the Commission exercise a power under the Rules of Procedure or change the Rules of Procedure;
- parties may file a procedural request to request the disclosure of information that has been designated as confidential; and
- procedural requests are to be made as soon as possible, put in writing to the Secretary General, and address how it might affect other persons. [emphasis added]
Given that the Notice of Consultation was published on 2 February 2017, that the data in question was filed with the Commission in March 2017, and that the record was open until 14 July 2017, your request should have been filed via a procedural request letter during that timeframe. To be clear, the sections of the three documents that you referenced in paragraph 3 of your letter were not and would not be considered procedural requests, but rather views expressed by your parties that have been added to the record of the proceeding as a matter of course.
Commission staff decision regarding request #1
Commission staff will not be requiring the disclosure of the requested information on the public record of the proceeding.
However, Commission staff notes that certain statistical data numbers that you are requesting are already available on the Closed Notices of Consultation section of the Commission’s website. Specifically, aggregate monthly call volumes are provided in a letter dated 27 March 2017 that responded to a procedural request filed by Bell Canada on 28 February 2017.
Request #2 that national statistical data reports be made available on an annual basis
Your letter also requests that the Commission encourage that national statistical data reports be made available on an annual basis so that groups such as Canadian Association of the Deaf, Deaf Wireless Canada Consultative Committee and Canadian National Society of the Deaf-Blind can access them when required.
Commission staff decision regarding request #2
Commission staff will not be making any determination, while the current proceeding is ongoing, on whether national statistical data reports should be made publicly available in the future.
In light of the above, Commission staff is returning your letter.
If you have any questions with regards to this matter, please contact Bradley Gaudet at email@example.com.
Director, Social and Consumer Policy
Consumer Affairs and Strategic Policy
c.c.: Distribution List
- Bell Aliant Regional Communications, LP firstname.lastname@example.org
- Bell Canada email@example.com
- Bragg Communications Inc. (Eastlink) firstname.lastname@example.org
- Canadian Hearing Society, email@example.com
- Canadian National Institute for the Blind, firstname.lastname@example.org
- Chris Newman email@example.com
- Cogeco firstname.lastname@example.org
- Conseil provincial du secteur des communications (CPSC) du Syndicat canadien de la fonction publique (SCFP) email@example.com
- Freedom Mobile Inc. firstname.lastname@example.org
- Maple Communications Group Inc. email@example.com
- Media Access Canada firstname.lastname@example.org
- MTS Inc. email@example.com
- Northwestel Inc. firstname.lastname@example.org
- Rogers Communications Inc. email@example.com; firstname.lastname@example.org
- Saskatchewan Telecommunications email@example.com
- Shaw Telecom Inc. firstname.lastname@example.org
- TBayTel email@example.com
- Télébec Limited Partnership firstname.lastname@example.org
- TELUS Communications Company email@example.com
- Vidéotron firstname.lastname@example.org
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