Telecom - Procedural Letter addressed to the Distribution List
Ottawa, 18 February 2022
RE: Introduction of Next Generation 9-1-1 (NG9-1-1) Service – Rogers Request for abridged versions of the ITPA-member SILECs responses to Request for Information and Rogers’ Request for an Extension Deadline re. Bell Tariff Notice 968 and TELUS Tariff Notice 565
On 7 February 2022, the Independent Telecommunications Providers Association (ITPA) submitted responses to Requests for Information (RFI) on behalf of its small incumbent local exchange carrier (SILEC) members. In their cover letter, the ITPA designated the RFI responses as confidential. The ITPA explained that the information contained trade secrets, and its disclosure could reasonably be expected to affect contractual and strategic negotiations, and relations between ITPA-members SILECs and their current suppliers involved in the provision of the NG9-1-1 services. The ITPA further explained that it did not file abridged version since removal of the confidential information would render the abridged versions meaningless. Instead, it prepared summaries of the models in order to provide parties with useful information for the purpose of preparing interventions.
On 11 February 2022, the Commission received a procedural request from Rogers Communication Canada Inc. (Rogers), in which Rogers requested that the ITPA-member SILECs file abridged versions of their RFI responses. Rogers submitted that the ITPA-member SILECs responses are inconsistent with Commission rules, which set out that at the time that a party files information it designates as confidential, it must provide an abridged version of the document along with an explanation of why the information should be considered confidential. Furthermore, Rogers noted that abridged versions of a document must only omit information which is designated confidential. Rogers added that itself and other interested interveners do not have enough material to provide any meaningful comments on the ITPA-member SILECs RFI filings. Rogers requested they be allowed 20 days to review the SILECs abridged fillings.
Staff also notes that Rogers filed an additional request for extension related to the delayed posting of RFI responses from Bell and TELUS on the CRTC website.
Staff notes that, as set out in section 32(2) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure), parties filing information it designates as confidential must provide an abridged version of the document that contains the confidential information or provide reasons, as well as any supporting documents, to explain why an abridged version cannot be filed. In addition, Broadcasting and Telecom Information Bulletin CRTC 2010-961(Information Bulletin 2010-961) explains that the abridged version of a document must omit only that information which is designated confidential. Information that is not itself inherently sensitive, such as tables of contents, headings and sentences that do not themselves contain information designated confidential, should not be omitted from the document. Essentially, the abridged version should not be edited in a manner that makes it difficult or impossible to determine the places where, and the extent to which, information has been omitted.
In line with the Commission’s Rules of Procedure and the Information Bulletin 2010-961, Commission staff requests ITPA-member SILECs to file abridged versions of their 7 February 2022 RFI responses. To provide parties with sufficient time to comment on the RFI responses from Bell Canada, TELUS, SaskTel, and the SILECs, the process is amended as follows:
- ITPA-member SILECs are to file abridged RFI responses, serving a copy on all parties, by 7 March 2022
- Parties may file comments with respect to RFI responses, serving a copy on all parties, by 21 March 2022
- Applicants may file replies to comments, serving a copy on all parties, by 4 April 2022
All documents filed and served must be received, not merely sent, by the date provided. Parties are to send an electronic copy of all documents to Commission staff copied on this letter.
The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey).
A copy of this letter and all related correspondence will be added to the public record of the proceeding.
Original signed by
Director, Competitor Services & Costing Implementation
c.c.: Stais Armstrong, CRTC, 819-997-9253, firstname.lastname@example.org;
Daniel Cardozo, CRTC, 819-962-5720, email@example.com;
B. Natraj (Nat Natraj), CRTC, 819-953-5081, firstname.lastname@example.org
Attach. (1) Tariff Notices
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