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Telecom - Staff Letter addressed to Jean-François Dumoulin (Iris Technologies Inc.)

Ottawa, 1 November 2024

Reference: 8000-C12-202306860

BY EMAIL

Jean-François Dumoulin
VP Regulatory and Government Affairs
Iris Technologies Inc.
403 - 16766 TransCanada Hwy,
Kirkland, QC, H9H 4M7
regulatory@iristel.com

Subject: Compliance with Wireless Public Alerting Requirements – Iris Technologies Inc.

In Telecom Regulatory Policy CRTC 2017-91 Footnote1 and CRTC decision 2018-108 Footnote2 , the Commission directed all Wireless Service Providers (WSP) with LTE or newer networks to implement Wireless Public Alerting (WPA) system on these networks. Among other regulatory obligations, compliance to WPA requirements also include participation in bi-annual test alertsFootnote3, responding to the Commission’s annual telecommunications surveyFootnote4, ensuring 100% of devices sold are WPA compatibleFootnote5, conforming to ATIS standardsFootnote6, and filing incident reports as necessaryFootnote7.

The NPAS enables emergency management organizations across Canada to warn the public about imminent or possible dangers to life and property such as floods, tornados, hazardous materials, fires, and other disasters. The full participation of WSPs is important for ensuring that the NPAS is effective in safeguarding and warning Canadians in emergency situations.

Commission staff’s review indicates that Iris Technologies Inc (Iristel) has been providing LTE network services to its subscribers since 2018. However, the staff notes that Iristel has not filed annual survey form 1412 [Wireless Public Alerting] for the last three years (2021, 2022 and 2023). This form is a part of the annual telecommunications survey and asks respondents to confirm the compliance status to WPA requirements i.e., whether all the devices they sell are WPA compatible, whether they regularly distribute public alerts on LTE and newer networks, and do they participate in bi-annual visible public test alerts.  

Given the information provided above, Commission staff requests that Iristel respond to the following requests for information (RFI), as well as provide any other comments that are relevant to the facts and situation identified in this letter:

  1. Has Iristel met WPA requirementsFootnote8 including interoperability of its network with the National Alert Aggregation and Dissemination (NAAD)Footnote9 system, maintaining its system with latest updates, and ensuring the distribution of public alerts over its networks?
  2. If the requirements in question 1 are met, please share details about how and when each of these were fulfilled, including a log or details of the public alerts to which Iristel has participated in the last calendar year.
  3. If the requirements in question 1 are not met, then please provide details about what obstacles have prevented Iristel from being compliant to WPA requirements and the specific plans Iristel has to overcome these obstacles to implement WPA on its applicable networks. Include the specific steps in this plan and the associated timeframes for implementation and eventual compliance to WPA requirements.

Failure to comply with the Commission’s WPA requirements without Commission’s approval of exemption order could have significant safety implications for Canadians. Commission staff encourage Iristel to work with the Commission to ensure that this essential service is available to all Iristel customers. Failure to do so could lead the Commission to pursue regulatory recourse, up to and including the imposition of administrative monetary penalty.

This letter and any subsequent submissions will be placed on the CRTC’s website and may be placed on the record of any future public proceedings on this matter. Please repeat the question before responding. As set out in section 39 of the Telecommunications ActFootnote10 and in Broadcasting and Telecom Information Bulletin, CRTC 2010-961Footnote11, 23 December 2010, parties may designate certain information as confidential. However, they must provide a detailed explanation as to 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 parties designate information as confidential, they 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.

The Commission requires all confidential 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.

Please submit your response no later than Friday November 22, 2024, by 5:00 p.m., Vancouver time. If you have any questions or require additional time, please contact Mr. Amjad Iqbal at (819) 360-2891 or via email at amjad.iqbal@crtc.gc.ca.

Sincerely,

Michael Crupi
Manager, Network Technology
Canadian Radio-television and Telecommunication Commission

c.c. regulatory@icewireless.com; jdumoulin@iristel.com; regulatory@karrier.one 

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