Telecom - Commission letter addressed to Various Parties Interested
Ottawa, 8 April 2021
Our reference: 1011-NOC2020-0326
BY EMAIL
Mr. Stephen Schmidt
Vice-President – Telecom Policy & Chief Regulatory Legal Counsel
Telecom Policy & Regulatory Affairs
TELUS Communications Inc.
regulatory.affairs@telus.com
Mr. Philippe Gauvin
Assistant General Counsel
Bell Canada
bell.regulatory@bell.ca
Mrs. Nathalie Blais
Research advisor
nblais@scfp.ca
RE: Establishment of new deadlines for Canada’s transition to next-generation 9-1-1, Telecom Notice of Consultation 2020-326 – Disclosure of information designated as confidential
Dear Mr. Schmidt, Mr. Gauvin, and Mrs. Blais:
This letter addresses a request for disclosure of information designated as confidential made in the above-mentioned proceeding associated with CRTC file number 1011-NOC2020-0326.
In their interventions concerning the responses to a Commission staff request for information dated 15 January 2021, le Comité 9-1-1 du Syndicat canadien de la fonction publique au Québec (le Comité 9-1-1) requested disclosure of information for which confidentiality had been claimed by TELUS Communications Inc. (TELUS) and Bell Canada (Bell).
Specifically, le Comité 9-1-1 requested that Bell disclose the typical volume of E9-1-1 calls that require default routing, presented as a percentage of all E9-1-1 calls transiting over its 9-1-1 network, and that Bell and TELUS disclose the estimated number of emergency call takers they will need to hire for their respective NG9-1-1 default call handling solutions, and the estimated average call handling time on which costs for Bell and TELUS’s respective NG9-1-1 default call handling solutions were based.
In letters dated 26 February 2021, TELUS and Bell opposed le Comité 9-1-1’s request.
Requests for disclosure of information designated as confidential and submitted in the context of a proceeding are addressed in light of sections 38 and 39 of the Telecommunications Act (the Act) and sections 30 and following of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure. In evaluating a request, an assessment is made as to whether the information falls into a category of information that can be designated confidential, pursuant to section 39 of the Act. An assessment is then made as to whether there is any specific direct harm likely to result from the disclosure and whether any such harm outweighs the public interest in disclosure.
In making this evaluation, a number of factors are taken into consideration and are discussed in more detail in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, as amended by Broadcasting and Telecom Information Bulletin CRTC 2010-961-1.
In the circumstances of this case, Commission staff considered, among other things, whether disclosure of the information would meaningfully benefit public participation given that the record for this proceeding is closed.
On the matter of the typical volume of Enhanced 9-1-1 (E9-1-1) calls that require default routing, presented as a percentage of all E9-1-1 calls transiting over its 9-1-1 network, Commission staff considers that Bell should disclose this information on the public record. While the process associated with TNoC 2020-326 is over such that there are no opportunities for parties to provide further submissions, staff nonetheless considers that there is a public interest in increasing the transparency of the Commission’s decision-making process. Staff is not convinced that the disclosure of a standalone percentage representing the volume of E9-1-1 calls that require default routing would be sufficient information to enable bad actors to ascertain Bell’s default routing for the purpose of targeting and negatively impacting its 9-1-1 networks.
On the matters of call centre staffing and call handling times, Commission staff considers that Bell and TELUS should not be made to disclose this information on the public record. The relevant issue under consideration relates to whether a 5% capacity for default routing solutions by NG9-1-1 network providers is appropriate for the purpose of NG9-1-1 cost studies and subsequent NG9-1-1 wholesale and retail tariffs, which will be submitted by NG9-1-1 network providers as part of a distinct proceeding that will allow public participation. Access by parties to specific information associated with staffing requirements or estimated call handling times is not necessary to inform the Commission’s eventual decision on the underlying issue as part of this proceeding.
Having regard to the above, Bell is to file, for inclusion on the public record, the typical volume of E9-1-1 calls that require default routing, presented as a percentage of all E9-1-1 calls transiting over its 9-1-1 network by 13 April 2021.
Sincerely,
Original signed by
Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector
c.c.: Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca
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