Telecom - Staff Letter addressed to Marc Nanni
Ottawa, 11 January 2024
Our reference: 1011-NOC2023-0039
By EMAIL
Marc Nanni
mn_crtc@proton.me
Subject: Telecom Notice of Consultation 2023-39 Call for comments – Development of a regulatory framework to improve network reliability and resilience – Mandatory notification and reporting about major telecommunications services outages (NOC 2023-39)
Dear Mr. Nanni,
This is further to your letter dated 1 December 2023 mainly with regard to the proceeding initiated by NOC 2023-39.
In your letter you requested that the Commission clarify whether “all Canadian carriers” includes satellite carriers, and the term “material portion” contained in the interim notification requirement and requested that the Commission issue a request for information (RFI) to Eastlink regarding a matter raised in an application filed by City Wide Communications Inc.
We note that the deadline for interventions in the NOC 2023-39 proceeding was 24 March 2023. The Commission extended that deadline to 3 October 2023 only to allow for interventions to be filed in American Sign Language (ASL) and Langue des signes québécoise (LSQ) by Canadians who are Deaf or Hard of Hearing, or their representatives, in video format and to allow for replies specifically to those interventions by 1 December 2023. Your intervention is therefore filed out of process and accordingly will not be placed on the record of this proceeding.
To assist, however, we will mention that satellite service providers can indeed be Canadian carriers to the extent that they own or operate transmission facilities that are used to provide telecommunications to the public for compensation. Accordingly, depending on the design of their network and what services they provide, satellite service providers are registered and identified on the lists of service providers on the CRTC website as non-dominant carriers, Wireless carriers, Basic International Telecommunications carriers or Other Carriers.
In your letter you also sought clarity on the term “material portion” with regards to the interim major service outage reporting requirement. This issue, along with the scope of service providers to whom the obligation to provide outage notification would apply, are issues being examined in the NOC 2023-39 proceeding and matters that the Commission will determine in its decision.
With regard to your comments in relation to the Part 1 Application filed by City Wide Communications Inc., et al regarding the TPIA service outage caused by Bragg Communications Inc., we note that all interested parties have the opportunity to submit comments in that proceeding in accordance with the process for Part 1 Applications set out in the CRTC Rules of Practice and Procedure. Matters concerning the issues raised in that Part 1 Application must be addressed in the proceeding triggered by that Application.
Yours sincerely,
Original signed by
Noah Moser
Director, Broadband and Network Engineering
Telecommunications Sector
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