ITS Canada fires back at commission over allowed Part VII

Intelligent Transportation Sys-tems Society of Canada (ITS Canada) has taken issue with a recent Part VII asking the CRTC to consider assigning the 511 three-digit code for purposes other than transportation. The group has fired back at the regulatory agency that it has not respected the procedures regarding these situations. The following is an excerpt of ITS Canada’s February 20 letter. ITS Canada and the Canada 511 Consortium are in receipt of a Part VII Application Respecting the Assignment of 511 filed with the Commission by the Canadian Association for Suicide Prevention / Association canadienne pour la prévention du suicide ("CASP/ACPS") on February 15, 2006. This letter addresses procedural matters only. The Part VII Application is another example of CASP/ACPS’s disregard for the Commission’s process, as established by Telecom Public Notice CRTC 2005-5, ITS Canada application for access code 511 ("PN 2005-5"). CASP/ACPS had more than an ample and fair opportunity to make an application for the allocation of 511 for suicide prevention services. Indeed, CASP/ACPS has corresponded with the Commission regarding its interest in 511 allocation on at least four occasions over a period of more than four years. Furthermore, CASP/ACPS was permitted by the Commission in the proceeding initiated by PN 2005-5 to file its initial comments, including new evidence, a day after the established deadline for reply comments. CASP/ACPS’s intervention outside of the established process was allowed despite full and fair notice to CASP/ACPS of the Commission’s prescribed procedures and with no valid explanation as to why CASP/ACPS did not comply with those procedures. ITS Canada and the Canada 511 Consortium have already expressed strong concerns with such abuse of process and disregard for the significant public and private resources that various parties have invested in participating in the PN 2005-5 proceeding. ITS Canada and the Canada 511 Consortium urge the Commission to respond to the CASP/ACPS Part VII Application in a manner that will maintain and respect the fairness of the public proceeding in PN 2005-5. This proceeding represents over a year’s worth of work by all parties, including the Commission. ITS Canada and the Canada 511 Consortium respectfully request that the Commission proceed with the CASP/ACPS Part VII Application in accordance with the standard procedures established in Sections 59-61 of CRTC Telecommunications Rules of Procedure (the "Rules") dealing with Part VII Applications. The Rules provide respondents with thirty days within which to provide an Answer to the Application and provide applicants with a ten-day period within which to provide a Reply to such Answer. The Rules also provide an opportunity for intervention by interested parties, and an opportunity for applicants and respondents to reply to such intervention. ITS Canada and the Canada 511 Consortium note that CASP/ACPS included a Notice calling for Answers to the Application to be filed within thirty days, consistent with the standard Part VII process just described. ITS Canada and the Canada 511 Consortium consider that their participation in the Part VII process initiated by the CASP/ACPS will be the most efficient way to respond in the circumstances, and will best ensure that the past year’s efforts will not have been in vain. Accordingly, ITS Canada and the Canada 511 Consortium will provide their answer to the CASP/ACPS Part VII Application within thirty days from the date of service of the Application, February 15, 2006.

ITS Canada fires back at commission over allowed Part VII

News | March 7, 2006

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