Canadian Ragiotlovsion and Conseil dea racousion et dos ‘Waecomenaniations Commission tigcommunicatons canagiomes ‘tans, Conte File no, 1011-NOCz018-0422 ‘Ottawa, 22 Novernter 2018 BY E-MAIL Mr. John Lawford Executive Director and General Counsel Public Interest Advecacy Centre, lawford@piae ca Me. Frank Feline President ‘Canadian Association ofthe Deat-Association des Sourds du Canada etal ffolino@cad.ca Me, Jl Schatz Executive Director ‘Canadian Network Operators Consortium, Me. Mark Nanni eta m nanni@hushmal.com Mr. Stephen Schmidt Vice-President - Telecom Policy & Chief Regulatory Legal Counsel ‘TELUS Communications inc. regulatory sffare@telus com Ce: Ms, Monica L. Auer Executive Director Forum for Research and Policy in Communications, execdin@tpenet Ms. Katrine Dilay ‘Attorney Manitoba Branch ofthe Consumers’ Association of Canada kadil@ple mb.ca Ms. Anais Beaulieu-Laporte Analyste poltiques st réglementation Union des consommateu abeaulieu Japorte(@uniondesconsommateurs.ca Distribution ListDear Madam or Si ‘Subject: Proceeding to establish a mandatory code for Internet services - Procedural Requests, (On 8 November 20°8, the CRTC published Call for comments ~ Proceeding to establish ‘a mandatory code for Internet services, Telecom Notice of Consultation CRTC 2018-422 ithe Notice) ‘The Notice sets outthe following schedule: 19 December 2018 Deadline fo submit intial comments 28 January 2018 Deadline to submit reply comments 21 March 2019 Deadline to submit responses to requests for information (RFIs), ‘which the Commission may ask of any party tothe proceeding, 8 Apri 2019 Deadline to submit final submissions ‘On 10 November 208, the Public Interest Advocacy Centre (PIAC) submitted a rocedealequestn whch asked tha the Commission. ‘Change the paper process ta an oral hearing due tothe importance of the proceeding: + Change the schedule for the proceeding due tothe ongoing proceeding on Report regarding the relal sales practioas of Canada’s large telecommunications camers" {and to provide all parties addtional ime to prepare their submissions. PIAC’s proposed schedule would, among other things, delay the ital comment deadline LntS Apri 2019 and all subsequent dates; and ++ Address PIAC’s concers regarding whether the Commission has already issued RFs to cortain partes, “The Forum for Research and Policy in Communications (FRPC), Union des consommateurs (UC), the Canadian Network Operators Consortium (CNOC), the Canadian Associaton of the Deat-Association des Sourds du Canada et al*(CAD-ASC etal), Mare Nanni Kelly McNamara, David Willam Hadcack (Mark Nanni etal), and the Manitoba Branch ofthe Consumers’ Association of Canada (CAC Manitoba) supported PIAC's request in tters dated 11, 12, 13, 14,15, and 21 November 2018, respectively Telus Communications Ine. (Telus), ints letter dated 16 November 2018, opposed PIAC’s request for an oral hearing, "Teccom nd oats Note of Craton CRTC 2018246 Canaan ton’ Soothe Gest nd (NSO), Dea Was Cane Conelaie Carine Co pores ‘Strices Sew ten Sout anna OUNSE CSC) and Conese ezasehaeny Nava Sana OAANG)In thei submissions, CNOC, CAD-ASC et al, and Telus proposed alternative schedules for the proceeding, First, with respect to PIAC’s request to hold an oral hearing, the Commission is ofthe view that the writer process set out in the Notice will provide a sufficient opportunity for Inlerested persons fo make submissions and for a complete record to be established With respect to the matters set out in the Notice. The Commission notes that the Television Service Provider Code (2016) was developed through a paper proceeding ‘Second, wth respect to PIAC and CNOC's requests thatthe deadline for intial submissions be moved toa date afer the publication of the Commission's ‘upcoming report on misleading and aggressive sales practices, the Commission ‘notes that in paragraph 2 of the Notice, it indicated that the two proceedings are ‘separate and that itis no in the public interest to delay a proceeding on the possible establishment of an Internet Code. With respect to PIAO's arguments that the deadlines should be adjusted to allow all parties more time to develop positions and commission research prior to fling intial submissions, ‘ne Commission is not convinced thatthe current schedule, \which allows 40 days before intial submissions are due, does not provide Sufficient time for al parties to make their intial comments \With respect o Telts’ proposal to change the order af submissions to permit parties to respond to RFs beloe intial submissions are fled, the Commission notes that the order ‘of submissions set outin the proceeding was deliberately chosen to allow the ‘Commission to effiiently and effectively complete the record ofthis proceeding While the Commission is ofthe view thatthe schedule and order of submissions ‘should remain as set out inthe Notice, the Commission considers that CAD-ASC. tet al, nas demonstrated that it requires a party-specific adjustment tothe {deadines set out in the Notice to prepare, conduct and submit the results of its proposed survey. The Commission notes that, in its letter, CAD-ASC et a ‘proposed to submitthe survey results on 7 March 2019. The Commission accepts the proposed timeline for submissions of CAD-ASC's survey. Finally, with respectto PIAC's concer relating tothe issuance of RFs, the ‘Commission clarifies that no RFIs have been sent to date. Consistent with the order of deadlines set out in the Notice, Commission RFs would be based on the evidence ‘submitted in intial and reply comment phases and, thus, sent after the reply phase Which clases on 28 January 2018, In light ofthe above, the Commission determines that: +The request to hold a public hearing is denied ‘+The requests for an extension tothe fling deadlines made by PIAC, CAD-ASC et al land CNOC are denied ‘+The request to change the order of submissions and associated timelines by Telus is, denies