Telecom and Broadcasting - Staff Letter addressed to Marc Nanni
Gatineau, 21 November 2025
Reference: 1011-NOC2025-0180
BY E-MAIL
Marc Nanni
mn_crtc@proton.me
Subject: Telecom and Broadcasting Notice of Consultation CRTC 2025-180, Call for comments - Improving the public alerting system — Two Procedural Requests Submitted by Marc Nanni
Commission staff have received your two procedural requests relating to the above-referenced proceeding.
In your first submission, with two correspondences dated 07 and 08 of October 2025, you asked that the Commission request that Pelmorex Communications Inc. (Pelmorex) file, on the record of this proceeding, the following:
- the most recent independent, third-party security audit of Pelmorex for the National Alert Aggregation and Dissemination (NAAD) system, conducted within the last 24 months; and,
- detailed annual financial statements for the NAAD system, since 2010, itemizing revenue from the television subscriber fee and detailing expenses related to system operations, maintenance, modernization, and security.
In your second submission, dated 12 November 2025, you requested that, in light of the proposal on Renewing Canada’s National Public Alerting System (NPAS) set out in the recent federal budget, Budget 2025 - Canada Strong, the Commission:
- issue a follow-up notice of consultation, with a 90-day comment period, focused explicitly on the architecture, governance, and principles of the future state of the NPAS;
- add to the public record the Commission’s relevant studies, performance monitoring, and test data related to the existing emergency alert system; and
- schedule a public hearing for 2026.
Staff views that with respect to your first procedural request, the requested information relates to the security, funding, governance and operation of the NAAD system and that these issues are not in scope of the proceeding. This proceeding focuses on the following targeted improvements to the NPAS:
- the accessibility of the NPAS for persons with disabilities;
- the language of alerts in the NPAS - official languages, Indigenous and additional languages;
- potential wireless public alerting gaps across the country;
- the test schedule for public alert tests; and
- ways to improve the Commission’s monitoring and validating of compliance with public alerting requirements.
Staff acknowledges your interventions which address these issues. Your interventions form part of the record which will be considered in this proceeding. However, the NoC sets out the scope of the issues to be considered in this proceeding, and a complete redesign of the NPAS and its future state are out of the scope of this current proceeding. Staff views that the additional information you seek from Pelmorex is not pertinent for the topics in scope of this proceeding.
With respect to your second procedural request, CRTC staff notes that the Commission regularly publishes information about the NPAS, as referenced below, which any interested person can consult at any time and address in their submissions:
- Location of Broadcast and Wireless Emergency Alert Distributors | CRTC incorporates the data sets and maps of the entities that report on compliance relating to the NPAS in annual surveys.
- National Public Alerting System – Implementation Summary - Open Government Portal provides summary of staff’s analysis on annual survey data for compliance relating to NPAS.
- Departmental Results Report 2023-24 | CRTC provides summary of departmental annual compliance targets and actual result reports (which address departmental results relating to public alerting).
- Staff reviews and investigates public inquiries related to NPAS matters in Telecom and Broadcasting.
Moreover, the details of the federal government proposals for the NPAS are unknown at this time and in staff’s view, it would be premature to propose altering the scope of the proceeding at this time.
In light of the above, Commission staff is of the view that there is no need to ask Pelmorex to provide the requested documents or to change the scope, timeline or procedures of this proceeding.
Commission staff takes note of you requested areas for further inquiry. Staff will keep these in mind when recommending further proceedings to the Commission.
Yours sincerely,
Simon Levasseur
Director, Financial and Multiplatform Technology Analysis
Canadian Radio-television and Telecommunications Commission
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