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Telecom - Commission Letter addressed to Philippe Gauvin (Bell Canada)

Ottawa, 26 April 2022

Our reference: 1011-NOC2020-0326

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
bell.regulatory@bell.ca

RE: Disclosure of information marked as confidential

Dear Philippe Gauvin,

The present is in response to a letter (the letter) filed by Bell Canada (Bell) with the Commission on 1 April 2022 in which Bell provided a status update on Originating Network Provider (ONP) Footnote1 production onboarding activities within the context of Next Generation 9-1-1 (NG9-1-1) implementation.

In the letter, Bell filed certain information in confidence, submitting that it was doing so in accordance with section 39 of the Telecommunications Act (the Act) and the directions provided by the Commission in Appendix to Broadcasting and Telecom Information Bulletin 2010-961. Bell further added that the information filed in confidence consists of technical information that Bell consistently treats as confidential and that pertains to individual ONPs’ competitively sensitive information.

In particular, Bell treated as confidential the names of entities Bell indicates as having so far been unresponsive to requests for physical connectivity to Bell’s NG9-1-1 network.

In Telecom Decision 2021-199 Footnote2 , the Commission directed

  1. Next generation 9-1-1 (NG9-1-1) network providers, by 1 March 2022, to establish their NG9-1-1 networks, complete all NG9-1-1 production onboarding activities, and be ready to provide NG9-1-1 Voice by transiting live NG9-1-1 traffic, wherever public safety answering points (PSAPs) have been established in a particular region; and
  2. Telecommunications Service Providers (TSPs), throughout their operating territories, to
    1. make the necessary changes to support NG9-1-1 Voice in their originating networks that are technically capable of supporting NG9-1-1 Voice, including completing all NG9-1-1 production onboarding activities, by 1 March 2022; and
    2. begin providing, by 1 March 2022, NG9-1-1 Voice to their customers served by networks that are technically capable of supporting NG9-1-1 Voice, wherever PSAPs have been established in a particular region by directing their NG9-1-1 Voice traffic to the appropriate NG9-1-1 points of interconnection (POIs).Footnote3

Pursuant to section 39 of the Act, Commission staff conducted an assessment as to whether the relevant information qualifies for confidential treatment and, if yes, whether there would be any specific direct harm likely to result from the disclosure of the information Bell has filed in confidence that would outweigh the public interest in disclosure.

Commission staff is of the view that information relating to a TSP’s responsiveness to Bell’s correspondence in relation to connectivity to Bell’s NG9-1-1 network for the purpose of meeting the obligations set out at paragraphs a) and b) above does not constitute information of a type over which confidentiality may be claimed. However, even presuming that such information can be properly designated as confidential, staff considers that there is a high public interest in disclosing information going to TSPs’ compliance with their NG9-1-1 obligations and that such public interest would outweigh any harm that could result from disclosure. Furthermore, staff considers that, to the extent that harm could result from disclosure of such information, such harm is within the control of the relevant TSP.

Having regard for the above, Commission staff considers it appropriate to provide Bell and the concerned ONPs (blind carbon copied on this letter) with an opportunity to comment on staff’s views as outlined in the preceding paragraph. Any answer is to be provided by 2 May 2022 and is to be served upon all recipients of this letter. In the event that no representations are filed with the Commission objecting to disclosure by 2 May 2022, Bell is to file, by 4 May 2022, for inclusion on the public record a modified version of the abridged letter disclosing the names of the entities whom Bell indicates have so far been unresponsive to requests for physical connectivity to Bell’s NG9-1-1 network.

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:  Étienne Robelin, etienne.robelin@crtc.gc.ca, 873-354-4325

b.c.c.: ONPs who, according to Bell, have so far been unresponsive to requests for physical connectivity to Bell’s NG9-1-1 network

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