ASL – Call for Comments (3 of 5)

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Call for Comments

In each of your responses to these questions, provide a rationale or evidence to support your responses, including any relevant technical, practical, or economic justification.

The first issue is “Principles that should guide the development and implementation of the resiliency regulatory policy”

Several principles could guide the Commission's resiliency regulatory policy. For example, the policy could consider that telecommunications service providers should, among other things:

  • strive for always-on service availability;
  • design resilient networks to withstand disruptions;
  • implement robust network operation processes;
  • aspire to have immediate fault mitigation and rapid restoration mechanisms;
  • deploy resilient communications networks for emergency recovery personnel;
  • strive for reliable partnerships with third-party vendors and suppliers; and
  • support each other during times of need.

Question: Which principles should the Commission consider in establishing the resiliency regulatory policy? How can each of these principles improve network resiliency and service reliability?

The next issue is “Improving the reliability of accessibility services”

Accessibility services are specialized telecommunications services used by persons with hearing or speech disabilities. Accessibility services addressed in this proceeding are teletypewriter relay and Internet Protocol relay services. Unlike emergency services, accessibility services are provided using regular telecommunications networks. The reliability of Video Relay Service was addressed in Telecom Notice of Consultation 2021-102 and will not be considered in this proceeding.

Question: What measures should telecommunications service providers implement to improve the reliability of teletypewriter relay and Internet Protocol relay services? Which of these measures should be mandatory, and which should be considered best practices? 

Question: What measures should third-party service providers, hired by the telecommunications service providers to provide teletypewriter relay and Internet Protocol relay services, implement to improve the reliability of those services?

  1. How can telecommunications service providers ensure these third-party service providers have implemented the required measures? 

The next issue is “Accessing telecommunications services during an emergency”

Canadians can take specific measures to ensure continued access to telecommunications services during emergencies, such as power outages, extreme weather events, and other natural disasters. The Commission establishes policies and requirements to ensure telecommunications service providers provide reliable services. Innovation, Science, and Economic Development Canada (ISED) is the telecommunications emergency preparedness liaison between the telecommunications industry and federal, provincial, and territorial emergency management organizations. As part of this role, ISED has provided Guidance for Canadians to stay connected during an emergency. The Canadian Telecommunications Association (CTA) advocates on behalf of telecommunications service providers and informs Canadians about industry initiatives such as consumer protection. The CTA has also provided guidance on Preparing for Severe Weather Events & Other Emergencies, outlining how Canadians can stay connected in the event of a natural disaster, a severe weather event, or an emergency.

Question: Given the guidance provided by ISED and the CTA on how Canadians can prepare and stay connected during emergencies,

  1. Is there additional information that telecommunications service providers should be responsible for providing to Canadians?
  2. Should telecommunications service providers be required to inform Canadians about how to prepare and stay connected during emergencies? If so, for which services, and what methods of communication should telecommunications service providers use?

The last issue is “Enforcing the resiliency regulatory policy”

The Commission may require telecommunications service providers to implement certain measures as an outcome of this proceeding. In those circumstances, the Commission may need to impose compliance and enforcement mechanisms.

Question: What specific compliance measures should the Commission consider to help ensure telecommunications service providers adhere to the resiliency regulatory policy requirements (e.g., compliance reporting, resiliency audits, or monitoring)?

  1. Should these compliance measures apply equally to all telecommunications service providers? If not, explain why.
  2. How could the Commission quantify and evaluate the resiliency of telecommunications service providers’ networks and the reliability of their services?

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The Commission is launching this notice of consultation to gather views on the measures that telecommunications service providers should take to help improve the resiliency of telecommunications networks and the reliability of telecommunications services.

This video describes the areas and questions in the consultation that may be of particular interest to persons with hearing or speech disabilities.

Notice of Consultation CRTC 2025-226

Consultation about improving the resiliency of telecommunications networks and reliability of telecommunications services

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