Holistic regulation: the way to go, says the CWTA to Telecom Policy Review Panel

The Canadian Wireless Telecommunications Association has told the Telecommunications Policy Review Panel that a holistic or smart approach to regulation is preferred over the current practice of regulation by multiple bodies. The following is an excerpt from the CWTA’s September 15 second-round comments to the panel. This scenario creates additional cost and unnecessary regulatory burden in service implementation and delivery. The implementation process for new services, for example, is often unduly lengthened by the fact that a variety of bodies or agencies, from different levels of government, may each attach various additional requirements to the service, even when another body has already considered the same issue or criteria. This scenario cannot be improved by increasing the number of regulators or oversight bodies, but this is precisely what certain parties have advocated. CWTA submits that a holistic - or "smart regulation" - approach to the regulation of the industry is warranted. By this we mean that the entire "regulatory package", i.e. all obligations established by governments and layered on the industry in pursuit of public policy objectives must be examined in concert, since the entire package is paid for by the wireless carrier and ultimately its subscribers.The CWTA submits that as the wireless market is competitive, regulation should be resorted to only where necessary. Such regulation should be implemented in the least obtrusive manner possible and only where the benefits clearly outweigh the costs. CWTA notes the comments of the Ontario 911 Association and wishes to reply to them here. CWTA and its members believe that 9-1-1 is an important service, as evidenced by the fact that wireless carriers have voluntarily provided their customers with access to this service from the outset. In the past, wireless carriers have developed and voluntarily offered their subscribers access to 9-1-1 services wherever local governments have established 9-1-1 service. Elsewhere wireless carriers have voluntarily provided their subscribers with access to other agencies such as provincial police, RCMP and others so that wireless 9-1-1 calls are always connected even where no wireline telephone 9-1-1 service is available.Contrary to the submission of the Ontario 911 Advisory Board, all four wireless carriers at the time in Canada chose to implement Phase 1 wireless E911 services in response to market forces, and well before the Commission issued Decision 2003-53. With respect to the Ontario 911 Advisory Board’s statement regarding wireless handsets pre-programmed to dial 9-1-1, it should be noted that wireless carriers generally have been responsive to such exhortations and have taken action some years ago in response to these concerns. The specific handset mentioned does not have a dial pad, and therefore would be unable to call emergency services at all if it was not pre-programmed to dial 9-1-1. In addition, the handset has a two-step dialing process that has been specifically designed to prevent accidental 9-1-1 calls. In keeping with the federal "smart regulation" initiative, CWTA submits there must be a reduction by government of the regulatory burden imposed on wireless carriers, through greater coordination between all government bodies that will have an impact on the industry. Justice Canada’s lawful access proposals are one example of pending government actions that could have a significant impact on the whole telecommunications industry.

Holistic regulation: the way to go, says the CWTA to Telecom Policy Review Panel

News | October 5, 2005

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