Telecom - Staff Letter addressed to Simon Desrochers (Cogeco Connexion Inc.)
Ottawa, 13 July 2023
Our reference: 8000-C12-201909780
VIA 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: Follow-up request for information regarding access to French language services during a VoIP 9-1-1 call
Dear Simon Desrochers,
On 5 May 2023, Commission staff issued a request for information to Cogeco Connexion Inc. (Cogeco) in relation to a situation covered by an article in Le Devoir,Footnote1 that occurred on 21 March 2023, in which Le Devoir reported that an individual was unable to access 9-1-1 services in French. The 9-1-1 call in question was made over a Voice Over Internet Protocol (VoIP) telephone service that was provided by Oxio and was received at the third-party call centre employed to confirm the caller’s location and manually route the 9-1-1 call to the appropriate Public Service Answering Point (PSAP). It was reported that Northern911 was the third-party call centre 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 communicate details related to their emergency in their preferred official language.
Commission staff has reviewed the responses provided by Cogeco on 10 May 2023 in relation to this incident.
Based on the responses including audio recordings provided, Commission staff is satisfied that Cogeco and Oxio were in compliance with their obligations to offer a service functionally equivalent to B9-1-1 by using a third-party call centre in order to confirm the caller’s location and manually route the call to the appropriate PSAP in accordance with Telecom Decision 2005-21, as well as the main emergency service obligations detailed in Telecom Circular 2008-2 in relation to the handling of disconnected calls. With regards to the availability of French language services to customers making 9-1-1 calls over their VoIP service, staff notes that Cogeco is currently working on a solution that ensures that Oxio’s Francophone customers can, at any time, reach French-speaking dispatchers in third-party emergency call centres. Cogeco stated in its response that it would expect a permanent solution to be implemented during the next quarter.
The above notwithstanding, staff requests that Cogeco provide the following additional information:
- by 28 July 2023, its plan regarding the integration of Oxio’s handling of 9-1-1 activities into its own operations, including all associated timelines;
- by 28 July 2023, evidence of Oxio’s compliance with direct-to-customer notifications (per Telecom Decision 2005-21 and 2005-61) that would have been provided to its customers prior to its acquisition by Cogeco; and
- by 30 September 2023, a detailed description of its permanent solution regarding French language access for its subscribers calling 9-1-1 via its VoIP service as well as a detailed description of any actions it is taking in the interim to prevent similar incidents from occurring again in the future.
Further, staff reminds Cogeco that, as the parent company to Oxio, it bears the ultimate responsibility to fulfill its due diligence both before and after acquiring other entities in terms of ensuring itself and its subsidiaries and/or affiliates are in compliance with 9-1-1 obligations established by the Commission.
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 it 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 this situation, 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.
Sincerely,
Original signed by
Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector
c.c.: Etienne Robelin, CRTC, etienne.robelin@crtc.gc.ca
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