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Telecom - Staff Letter addressed to Janet Lo (Commission for Complaints for Telecom-Television Services) and the Distribution List

Gatineau, 21 March 2025

Our Reference: 8665-J136-202406438

BY E-MAIL

Distribution List

Janet Lo
Assistant Commissioner, Legal, Regulatory & Stakeholder Affairs
Commission for Complaints for Telecom-Television Services (CCTS)
regulatory@ccts-cprst.ca

Subject: Request for information to CCTS regarding certain matters raised in the Part 1 application 2024-0643-8

Dear Janet Lo,

After a thorough review of the record for the Part 1 Application - InnSys Inc. - Participation of smaller Internet Service Providers (ISPs) in the CCTS, Canadian Radio-television and Telecommunications Commission (CRTC) staff considers that additional information from CCTS is needed.

Therefore, CCTS is required to answer questions presented in the appendix of this Request for Information (RFI) by the deadline of 31 March 2025. The responses must be limited to responding to the RFI and cannot introduce any new topics.

Following the submission of the responses to the RFIs by the CCTS, intervening parties (CanWISP, ITPA, CTA, Marc Nanni) can respond before 10 April 2025.

InnSys Inc. will be given until 22 April 2025 to present a final reply.

Procedures for Filing Documents

The CRTC requires that you submit your documents electronically by using the secured service "My CRTC Account" (Partner Log In or GC Key) and filling in the Telecom Cover Page.  On this web page, you will also find a link to information on the submission of applications to the Commission “Submitting applications and other documents to the CRTC using My CRTC Account.”

Forms and My CRTC Account | CRTC: Links that allow you to submit a broadcasting or telecommunications application, use other forms and submit documents to the CRTC.

Please file your response to this letter no later than 31 March 2025 and ensure that it is addressed to: Luke Smith / Social and Consumer Policy, please indicate process number: Part 1 application 2024-0643-8.

Filing of Confidential Information

Sections 30 to 34 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure and Broadcasting and Telecom Information Bulletin CRTC 2010-961 provide that persons can designate certain information submitted to the CRTC as confidential. A detailed explanation of why the designated information is confidential and why its disclosure would not be in the public interest must be provided, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in its disclosure.

If you file a document containing confidential information, you must also file an abridged version of the document omitting only the confidential information. Alternatively, you must give reasons why an abridged version cannot be filed. Only the abridged version of the document will be placed on the public record and posted on the CRTC’s website.

Yours sincerely,

Nanao Kachi
Director, Social and Consumer Policy

c.c.: Luke Smith, luke.smith@crtc.gc.ca
Michael Ostroff, michael.ostroff@crtc.gc.ca

Distribution List

regulatory@ccts-cprst.ca
mn_crtc@proton.me
executivedirector@canwisp.ca
jonathan.holmes@itpa.ca
ckatoch@canadatelecoms.ca
praba@innsys.ca

Appendix – Request for information to CCTS regarding certain matters raised in the Part 1 Application 2024-0643-8

  1. Given the consultation process outlined in paragraph 44 of the CCTS intervention and the objective of balancing diverse stakeholder interests mentioned in paragraph 45, elaborate on how the viewpoints of stakeholders with annual revenues less than $10 million were gathered and incorporated? Provide examples.

  2. Provide financial information from the past three fiscal years. Indicate:

    1. the totals for complaints-based fees, and annual fees for Participating Service Providers (PSPs) above $10 million in revenues, the total number of PSPs captured in this total, and the total number of complaints received for each PSP.
    2. the totals for complaints-based fees, and annual fees for PSPs under $10 million in revenues, the total number of PSPs captured in this total, and the total number of complaints received for each PSP.

    You are also asked to identify outliers (eg 2022 Rogers outage) in the data if present.

  3. Outline the fees charged at each stage of the complaint-handling process for each of the past three fiscal years, and explain how that formula was developed and/or how those amounts were decided.
  4. Provide details on how many PSPs failed to pay the outstanding fees of the CCTS for each of the past three fiscal years, specifically the total owed to the CCTS by each PSP, and the steps taken to address the outstanding balances. Indicate the PSPs above $10 million in revenues, and the PSPs below $10 million.
  5. In paragraph 63 of the CCTS intervention, the process for disputing billing errors is outlined. Describe this mechanism in more detail and include details on what would be in the scope for this dispute mechanism.
  6. In line with the 2023 Order Issuing a Direction to CRTC on a Renewed Approach to Telecommunication Policy, to what extent does the CCTS consider the impact on new market entrants and service providers that are smaller than the incumbent national providers, particularly those with less than $10 million in revenues, including their ability to pay, when setting the fee structure?
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