ARCHIVED - Telecom Procedural Letter Addressed to Various Parties

Ottawa, 1 March 2018                                                   

Our reference: 1011-NOC2017-0450

BY EMAIL
Distribution list and interveners

Telecom Notice of Consultation CRTC 2017-450 - Call for comments - Review of the reseller registration obligation

Dear Madam, Sir,

Pursuant to the procedure set out in Review of the reseller obligation, Telecom Notice of Consultation CRTC 2017-450, 15 December 2017, attached in an Appendix are the Commission’s requests for information to parties followed by an extra question to TELUS Communications Inc.

Responses to the requests for information are to be filed and served on interveners by 21 March 2018.  The responses will be available for all parties on the Commission’s website.

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.

Yours sincerely,

Original signed by Philippe Tousignant

Philippe Tousignant
Director, Planning, Research & Reporting

Interveners:

Communications Distributors, Inc., shannon@commdistinc.com
Steven Shearer, shearer_steven@hotmail.com
British Columbia Broadband Association (BCBA), regulatory@bcba.ca
Cybera Inc., alyssa.moore@cybera.ca
Lewis Birnberg Hanet, LLP, mlewis@lbhmedialaw.com
Coalition pour le service 9-1-1 au Québec, sallen@agence911.org
FCA Canada Inc., mlewis@lbhmedialaw.com
Geotab Inc., randeep.nijjar@bakermckenzie.com
Independent Telecommunications Providers Association, jonathan.holmes@itpa.ca
Public Interest Advocacy Centre, bsegel-brown@piac.ca
IBM Canada Ltd., snellm@ibm.com
University of Alberta, brstewar@ualberta.ca
McLean & Kerr LLP, lkroumova@mcleankerr.com
Canadian Network Operators Consortium Inc., regulatory@cnoc.ca
Québecor Média inc., dennis.beland@quebecor.com
TELUS Communications Inc., molly.samuelson@telus.com
The Toronto Internet Exchange, president@porix.ca
Queen’s University, gbuck@mccarthy.ca
Cogeco Communications Inc., michel.messier@cogeco.com

Distribution List:

Large incumbent local exchange carriers
Small incumbent local exchange carriers
Competitive local exchange carriers
Wireless carriers
Resellers of telecommunications services
Resellers of high-speed retail Internet services
Digital subscriber line service providers
Competitive pay telephone service providers

Appendix

Question for all parties

Question 1 – Telus Communication Inc.’s (Telus) proposal on registration criteria

Telus proposed four successive criteria that would enable the Commission to delineate between providers that would be eligible to be excluded from the registration obligation.  The four criteria are identified in paragraph 12 and Appendix 1 of Telus’ intervention.

Indicate, with supporting rationale, whether or not you support this approach.

Question 2 – exemption for M2M & IoT

Several parties discussed possible exceptions to the registration requirement for machine-to-machine (M2M) and internet of things (IoT) services due to the rapid evolution of this market and technology (i.e. entities who only provide M2M or IoT services, and no other services, would not be required to register at this time).

Parties proposed that an entity who only provides M2M or IoT services listed below could be exempted from the registration requirement at this time:

• to a predefined endpoint
• that do not require human intervention
• that do not permit human intervention
• that do not enable two-way communication (i.e. all communication is one-direction only)

Indicate, with supporting rationale, whether or not you support this approach and whether such an exemption would be appropriate at this time.  

Question 3 – Burden of current registration and reporting requirement

Some parties stated that they consider the current registration and reporting requirement to be unduly burdensome on resellers. The registration process is as follows.

• In order for an entity to be registered, the resellers must
  1. First, file a letter with the Commission that contains the following information
     • The company’s contact information;
     • A contact person and their contact information; and
     • The type of services the reseller will provide.
  2. Second, the reseller must confirm the above information through the Commission’s secure Data Collection System.
• The yearly reporting process is as follows
  1. Confirm the company’s contact information
  2. Confirm the contact person’s contact information; and
  3. Provide its annual revenue
  1. Indicate whether or not the registration process should be streamlined while continuing to provide this necessary information to the Commission. If so, explain in detail how the registration process should be streamlined.
  2. If you consider the registration and reporting process to be unduly burdensome, provide an estimate of the time and cost for you to meet this requirement. 

Question 4 – Monitoring burden for carriers and resellers

Telecom Regulatory Policy 2017-11 stated the Commission expects Canadian carriers and non-carriers to actively monitor and enforce the obligation for non-carriers to which they offer and provide telecommunications services to register with the Commission prior to receiving such services. Some parties stated that monitoring M2M, IoT and Wi-Fi providers would create significant administrative burdens.

Indicate, whether or not you consider the monitoring requirement to be burdensome. If so, provide an estimate of the time and cost necessary for an entity to meet this requirement and put forward quantifiable information to substantiate your argument.

Question 5 – Queen’s University’s proposal

Should the registration requirement be limited to telecommunications service providers (TSPs) (excluding Canadian carriers) who provide, or enable others to provide, basic telecommunications services to the public for compensation.

Indicate, with supporting rationale, whether or not you support this approach.

Question for TELUS

In its intervention, TELUS Communications Inc. (TELUS) proposed four successive criteria.  Criteria three in paragraph 12(c) stats: is the telecommunications service(s) being provided by the entity in question sufficiently commingled to be considered merely an ancillary component of the overall product offering.

Further explain the meaning of the criteria proposed in paragraph 12(c) and provide a plain language version of this criteria with examples.

Date modified:

y2018-03-01