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2010/06/09

CCTS’s Constating Documents

Filed under: Uncategorized — RogersWatch @ 20:39
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Discovery of the the CCTS Constating Documents:

One funny thing I came across in examining the CRTC 2010 review of the CCTS was the existence of the “constating” documents of the CCTS, which are in essence the organ’s incepting and governing docs. Funny, in that for the CCTS being quite ‘transparent’ and all and having a helpful, simple, informative website … there’s no record of these constating documents on the CCTS site, nor TTBOMK even mention of them. I emailed them the suggestion that they might post those docs on their website but haven’t heard anything back.

 

2008 Docs:

The original CCTS constating docs were submitted to the CRTC on August 5, 2008 and are located here:
— — http://www.crtc.gc.ca/public/partvii/2007/8638/c12_200719099/935111.zip

They include:

– the Procedural Code
– Corporate By-Law #1, which is the entire body of corporate by-laws, and spells out the usual corporate things
– the TSP Membership Agreement
– and esp Schedule E of the Membership Agreement (the “Complaint Level Costs for Eligible Complaints”), yet this Schedule is empty/redacted

 

2010 Docs:

On 31 May 2010 the CCTS submitted a response to the CRTC’s review of them:
— — http://crtc.gc.ca/public/partvii/2010/8665/c12_201007229/1400969.zip

It’s comprised of 19 PDF documents:
– 3 of which are specific Response to Interrogatories,
– 2 of which are a cover letter and an introduction,
– and the remainder which are Appendices (including the Letters Patent this time).

What’s curious is that the Response to Interrogatory titled “30Apr10-1 TNC 2010-247” (filename: “…DOCS-#1400973…”), wherein the CCTS responds to the CRTC’s request for a filing of a copy of the all the constating documents, refers to a large number of Appendices: 1-16, most with [a] and [b] subsets. However many of these Appendices are outright missing from the CCTS submission; most notably though is the absence of the Membership Agreement.

I’ll send off to them an email asking about this and see what they have to say about it.

Update: Apparently the missing 2010 docs was a CRTC problem it’s been corrected.

The CCTS is turning out to be a much more curious thing than I had originally thought, especially since they really, really want to withhold Schedule E of the Membership Agreement: “It is the view of the CCTS that disclosure of this information on the public record would undermine the operation of CCTS’s complaint resolution process.” This schedule documents how much each carrier has had to contribute to the funding of the CCTS, because the formula is partly based on carrier’s market share (which is no secret) and partly based on complaint share).

Pray tell, how would divulging complaint shares (and consequent contribution levels by individual TSP’s) “undermine the operation of CCTS’s complaint resolution process”, especially when the CCTS makes such complaint-share breakdowns already known by way of its annual reports (e.g. PDF page 20 of the 2009 Annual Report, here)?

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