Telecom - Staff Letter addressed to the Distribution List
Ottawa-Gatineau, 3 February 2025
Our reference: 8000-P114-202404929
BY EMAIL
Distribution list
Subject: Request for Information regarding an application by the British Columbia Ministry of Citizen’s Services
The CRTC has received an application from the British Columbia Ministry of Citizens' Services (the BC Ministry) requesting that certain current and future Annual Facilities Survey data be made publicly available. The BC Ministry requests that this information be made available by provider, technology, and speed at the 250-meter road segment level. The information provided by Telecommunication Service Providers (TSPs) is currently only publicly available at the 25km² hexagon level. For example, Innovation, Science and Economic Development Canada’s National Broadband Internet Service Availability Map displays aggregate coverage data for speeds at the 250-meter road segment level, but provider and technology data only at the 25km² hexagon level.
The BC Ministry is of the view that making more granular broadband and mobile data public is essential to serving the public interest since it will better enable infrastructure planning to address connectivity gaps and ensure equitable access to telecommunications services.
Similar mapping tools have been implemented in the USA Footnote1, UK, Footnote2Australia Footnote3, and the province of Québec Footnote4. In each case, granular data on connectivity options are provided at the civic address level.
In their submissions, several TSPs acknowledge that they provide information on their available services to the public upon request (e.g. by phone, online), but opposed the BC Ministry request on the grounds that the information could be used to benefit their competitors. For example, in its intervention, Rogers stated:
Rogers’ service address look-up tool is a convenient method for current and potential customers to verify that Rogers provides services to an address. Our customers use it to query a small number of addresses – for example, when they are looking to move to a new residence. It is not designed for consumers to query a large number of addresses, as consumers generally do not need to verify service availability at more than a handful of locations. To this end, our online address look-up tool will only allow consumers to make a limited number of queries before redirecting them to Rogers’ phone support for further assistance.
By restricting our online look-up tool to a small number of queries, we are limiting the ability of our competitors to take advantage of the tool to gain valuable information about our network deployments without compromising our customers. Should our competitors have unfettered access to detailed information about our last-mile networks, they will be able to artificially outmanoeuver Rogers in the market. For example, a competitor could use the tool to detect neighbourhoods where Rogers has recently upgraded its service offerings; it could then offer highly targeted promotions in those neighbourhoods to win market share.
The BC Ministry emphasized its commitment to safeguards to protect the underlying data used in the ISED Map. It clarified that it does not propose making this data publicly accessible or allowing users to perform bulk address searches.
Considering the above, TSPs are requested to provide the following information:
- What policies and procedures do you currently have in place to prevent bulk queries of service information?
- If the Commission were to allow TSP technology and speed data at the 250-meter road segment level to be made available to the public in a database searchable by address, what restrictions should be put in place to prevent bulk queries to protect the data?
TSPs are to submit their responses to this RFI no later than 28 February 2025. Parties can submit comments on the responses provided by TSPs no later than 14 March 2025. All documents filed must be received, not merely sent, by the date provided.
All related correspondence will be public. As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation for 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, a person designating information as confidential 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. If filing confidential information, the Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on the Commission’s website.
If you have any questions regarding this letter, please contact Bartek Bober by phone at (819) 230-0725 or by email at: bartek.bober@crtc.gc.ca.
Thank you, in advance, for your cooperation.
Sincerely,
Mark Allen
Senior Manager, Market Intelligence
Consumer, Analytics, and Strategy
Cc: Bartek Bober, Manager, Consumer, Analytics, and Strategy, bartek.bober@crtc.gc.ca
Distribution List:
Tom Blackwood, tblackw5@gmail.com
Tony Giligan, tony.gilligan@ecomm911.ca
Susan Church, susan.church@blueskyregion.ca
Ben Arril, ben.arril@gov.bc.ca
Cheryl Hansen, claude.innes@gnb.ca
Pierre Desmarteau, Pierre.Desmarteau@mce.gouv.qc.ca
Stefanie Corbett, lmacmillan@gov.pe.ca
LeBourdais, Maureen A, mlebourdais@cariboord.ca
Michael Riis-Christianson, michael.riischristianson@rdbn.bc.ca
Panneton Valérie, vpanneton@ctal.ca
Jonathan Veale, jonathan.veale@novascotia.ca
Rob Gay, rob11gay@gmail.com
Susan Clovechok, director.clovechok@rdek.bc.ca
Adela Wan, adela.wan@ontario.ca
Andrea Newell, anewell@houston.ca
Roel Coert, roel.coert@i-valley.ca
Owen Torgerson, otorgerson@valemount.ca
Walter Popoff, wpopoff@rdck.bc.ca
Nellie Davis, nellie.davis@rdbn.bc.ca
Ben Campbell, ben@northerndevelopment.bc.ca
Martin Elphee, district@fortstjames.ca
Reiko Tagami, rtagami@ubcm.ca
Warren Noga, warren@rmalberta.com
Johanna Helbig, jhelbig@coastalfirstnations.ca
Neil Smellie, neil@canwisp.ca
Judy Greenaway, judy.greenaway@rdbn.bc.ca
Michael McNally, mmcnally@ualberta.ca
Byron Holland, byron.holland@cira.ca
Bill Payne, bill.payne@haltonpolice.ca
Philippe Gauvin, bell.regulatory@bell.ca
Imran Mohiuddin, imran.mohiuddin@cybera.ca
Richard Bates, richard.bates@gov.ab.ca
Steve Mark, smark@icisociety.ca
Rob McMahon, info@firstmile.ca
Marielle Wilson, regulatory.matters@corp.eastlink.ca
Geoffrey (Geoff) White, gwhite@piac.ca
Andy Kaplan-Myrth, regulatory@teksavvy.ca
Jonathan Holmes, jonathan.holmes@itpa.ca
Kevin Spelay, document.control@sasktel.com
Howard Slawner, regulatory@rci.rogers.com
Cindy Wallace, cindy.wallace@xplore.ca
Erin Ruttan, erin.ruttan@calgary.ca
Kim Miller, kim.miller@telus.com
Melanie Cardin, regaffairs@quebecor.com
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