OTTAWA – A group of ten academics have told the CRTC that they will be unable to participate in the Internet code of conduct proceedings because the Commission’s timelines are too tight.
In a letter to CRTC secretary general Claude Doucet dated December 5, the group stresses that the 40 calendar day/28 business day timeline for parties to prepare initial comments is insufficient to “produce informed, high quality, evidence-based interventions”, and that “adherence to the timelines as proposed will exclude the perspectives of many Canadians, and is not in the public interest.”
“As noted in the correspondence from other public interest advocacy groups and individuals interested in intervening, all of the work necessary to contribute to the record of a CRTC proceeding must be conducted while also fulfilling other position responsibilities”, reads the letter. “For academics, teaching responsibilities (e.g. course preparation, classroom teaching, graduate student supervision and end of term assessment) simply cannot be set aside to work on unanticipated regulatory consultations. Other time-sensitive academic responsibilities include administrative work within our institutions, PhD studies, grant applications, managing other research projects and disseminating our findings (via academic and non-academic publications, presentations, and through participation in CRTC and other consultations, e.g. the ongoing review of Canada’s broadcasting and telecommunications legislative frameworks).”
The academics said that they have analyzed and “contributed extensively” to other CRTC consultations, including the initial development and subsequent review of the Wireless Code of Conduct (leading to Telecom Regulatory Policies 2013-271 and 2017-200), the creation of Quality of Service metrics for high-quality Internet service, the Review of Basic Telecommunications Services (leading to Telecom Regulatory Policy 2016-496), and the recent consultation to inform the preparation of a report on the retail sales practices of Canada’s large teleco carriers (Telecom and Broadcasting Notice of Consultation CRTC 2018-246).
The letter echoes the sentiments of the Public Interest Advocacy Centre (PIAC) who last month told the CRTC that it was boycotting the proceeding after the Commission denied its request for more time and for revisions to the proposed procedure.
