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Telecom - Staff Letter addressed to Simon Desrochers (Cogeco Connexion Inc.)

Ottawa, 5 May 2023

Our reference: 8000-C12-201909780

BY EMAIL

Simon Desrochers
Advisor, Regulatory Affairs, Telecom
Cogeco Connexion Inc.
1 Place Ville Marie
Bureau 3301
Montreal, QC, H3B 3N2
simon.desrochers@cogeco.com

Subject: Request for information regarding access to French language services during a VoIP 9-1-1 call

Dear Simon Desrochers,

Commission staff was recently informed of a situation that occurred on 21 March 2023, in which an individual was unable to access services in French when their 9-1-1 call, made over a voice over Internet Protocol (VoIP) telephone service, was received at the third-party call center employed to confirm the caller’s location and manually route the 9-1-1 call to the appropriate Public Service Answering Point (PSAP). According to news articles on this matter,Footnote1 the individual’s VoIP service provider during this event was Oxio, which is reported to have been recently acquired by Cogeco Connexion Inc. (Cogeco). In addition, it was reported that Northern911 was the third-party call center that treated the 9-1-1 call in question. 

The Canadian public and the Commission place a high degree of importance on being able to access timely and effective 9-1-1 services, including the ability for Canadians to be able to communicate details related to their emergency in their preferred official language. As such, and in accordance with section 37 of the Telecommunications Act, Cogeco is required to provide comprehensive answers to the questions set out below, including all relevant details, rationale and any supporting information, by 10 May 2023.

  1. Describe the complete sequence of events related to the incident covered by the article in Le Devoir, clearly indicating, in sequence, the details of the routing of the relevant call(s) (including location), and any role played by Cogeco, its subsidiary Oxio, and any third party, including the third-party call center.
  2. Confirm where the third party call centre routed the call. If this was to a PSAP, indicate which one. If it was not routed to a PSAP, explain why.
  3. Confirm the name of the third party call centre involved in the event in question and provide a copy of the service agreement or contract outlining its responsibilities to Cogeco or its subsidiary Oxio relative to the processing and routing of 9-1-1 calls to PSAPs.
  4. Provide details on any existing provisions in the service agreement regarding the provision of French language or bilingual services by the third party call centre to callers to 9-1-1 callers.
  5. Explain whether, according to Cogeco or its subsidiary Oxio, there has been any breach of the contract terms, particularly with regard to routing the call to a PSAP serving the location of the emergency and providing services in French, if any, in the context of the events described in the news articles.
  6. In the event that the contract does not provide for the provision of call processing services in French, please explain why
  7. Provide details of any communication Cogeco (or its subsidiary) has had with its third-party call center in relation to this event, including the relevant dates and nature of the correspondence. 
  8. Confirm and describe the means through which callers using Cogeco’s VoIP service to make 9-1-1 calls can access services in French when connected to the third-party call center employed by Cogeco for the purpose of having the location of VoIP 9-1-1 calls manually determined then routed to the appropriate PSAP. Cogeco is to provide the list of means in order of precedence (primary, alternate, tertiary, etc.) as well as an explanation of the circumstances in which one means is leveraged over the other(s). 
  9. Explain, if applicable, why such means were not used during the situation in question, resulting in the inability of the customer to communicate with the operator of the third-party call center in French. In the event that such means were used, explain why the caller was unable to obtain services in French.
  10. Explain what actions Cogeco has taken and/or intends to take to avoid this situation being repeated in the future. For each action or measure, specify the steps and relevant dates and timelines.
  11. Provide any additional details relevant to the Commission having a complete understanding of the situation not already covered by the above questions.

This letter and any subsequent correspondence will be placed on the CRTC’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, Cogeco may designate certain information as confidential though 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, should Cogeco designate information as confidential, Cogeco 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.

Note that, in accordance with its normal practices, the Commission may disclose or require the disclosure of information designated as confidential if it determines its disclosure is in the public interest, i.e., where the specific direct harm does not outweigh the public interest in disclosure.

In light of the public interest in understanding what happened, Commission staff expects Cogeco to disclose information to the maximum extent possible. Where a document is to be filed, the document must be actually received, not merely sent, by that date.

The Commission requires all documents to be submitted electronically by using the secured service “My CRTC Account” Partner Log In or GCKey and filing the “Telecom Cover Page” located on that web page.

Yours sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Étienne Robelin, Manager, Emergency Services, CRTC, Étienne.robelin@crtc.gc.ca

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