Abridged

2019 07 24

To: Mr. Claude Doucet

Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario
K1A 0N2

Subject: Part 1 Application for Commission approval to allow the Bell Companies to
temporarily block certain verified fraudulent and scam voice calls on a trial
basis under section 36 of the Telecommunications Act

Dear Mr. Doucet,

I Introduction

1. Bell Canada hereby files this Part 1 Application on its own behalf and on behalf of all of
its subsidiaries that carry voice traffic (collectively, Bell) pursuant to sections 36, 60 and
61 of the Telecommunications Act (the Act) and Part I of the Canadian Radio-television
and Telecommunications Commission Rules of Practice and Procedure (the Rules).

2. By this Part 1 Application we hereby request the Commission's approval, pursuant to

section 36 of the Act, to conduct a 90-day trial to block certain known, verified, fraudulent
scam voice telephony calls ("Verified Fraud Calls") received or transmitted from, to, or
over our networks.

3. Consistent with our past submissions to the Commission addressing potential remedies
to combat nuisance and fraudulent calling, we remain alert to the risk of placing too
much information about this trial on the public record. As always, the challenge is to
balance the significant risk of signaling to bad actors our detection mechanisms and
thereby providing a 'how to' road map that could be used to thwart this proposed anti-
nuisance calling proposal against the need to provide sufficient notice of the proposal to
potentially impacted parties.

4. Consistent with this balance, we hereby claim confidentiality under section 39 of the
Telecommunications Act on certain information contained in this Part 1 Application and
the confidential Attachment hereto that describe the blocking technology and
methodologies we propose to trial1. The disclosure of these matters, such that they

1 This information is filed in confidence with the Commission pursuant to section 39 of the Telecommunications Act
and the directions provided by the Commission in the Appendix to Broadcasting and Telecom Information Bulletin
CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission
proceedings, dated 23 December 2010, as amended in Broadcasting and Telecom Information Bulletin CRTC
2010-961-1, dated 26 October 2012.
Bell Canada
Philippe Gauvin
Floor 19
160 Elgin Street
Ottawa, Ontario K2P 2C4

Telephone: (613) 785-6286

Facsimile: (613) 560-0472
bell.regulatory@bell.ca
2019 07 24 Abridged 2

became available to parties 


2019 07 24 Abridged 2

engaged in fraudulent and scam calling, could reasonably be expected to result in material gain
to the bad actors and perpetuate the significant financial harms to Canadians targeted by their
scams. Consistent with principles of natural justice and the rights of interested parties to
sufficient notice, we are providing a copy of this letter to the following categories of
Telecommunications Service Providers (TSPs) appearing on the Commission's registration lists:
competitive local exchange carriers (CLECs), incumbent local exchange carriers (ILECs), small
incumbent local exchange carriers (SILECs), Other Carriers, and Wireless Carriers. This will
provide these service providers with sufficient notice and the point of contact within Bell,
traceback@bell.ca, in the event they need to contact us with concerns or have inquiries relating
to remediation measures arising from this proposal.

II Background

5. In CETRP 2018-4842 the Commission directed that as a condition of offering and

providing voice telecommunications services Canadian carriers and TSPs must
implement network-level call blocking. The Commission explained in the first paragraph
of that decision that:

In Compliance and Enforcement and Telecom Regulatory Policy 2016-442 the

Commission concluded that:

− universal network-level call blocking is the most effective and efficient

solution to manage nuisance calls in cases where it is possible to
accurately identify blatantly illegitimate caller identification (caller ID)
spoofing; and
− the use of universal network-level call blocking would ensure that
Canadians benefit from a minimum level of protection against nuisance
calls by fully addressing those that contain caller ID information that is
blatantly illegitimate.3

6. Thus, in CETRP 2018-484, the Commissioned ordered all TSPs to block calls
terminating on their networks where the caller ID: (i) exceeds 15 digits, or (ii) is
malformed and does not conform to a dialable number for calls initiated under the North
American Numbering Plan. The deadline for meeting this condition, or, alternatively,
implementing call filtering, is 18 December 2019.

7. In anticipation of this requirement, we have reconfigured our SS7 networks and

deployed blocking tools at our consolidated SS7 gateways and international gateways.

8. We expect to launch our network level universal call blocking initiative in compliance with
the above CETRP 2018-484 condition in the fall of 2019. We are in the process of
finalizing the customer bill notifications, SMS text notifications and website descriptions
of the mandated universal call blocking measure as part of the Commission's mandated
notification and disclosure requirements so that these are completed 60 or more days in
advance of the launch of our network call blocking. We are also finalizing the
arrangements so that our redress mechanisms are launched coincident with the
universal network level call blocking launch.

2 Compliance and Enforcement and Telecom Regulatory Policy CRTC 2018-484, Implementation of universal
network-level blocking of calls with blatantly illegitimate caller identification, paragraph 44.

3 CETRP 2018-484, paragraph 1 [original footnote omitted].

2019 07 24 Abridged 3

9. However, we believe we can build upon the above blocking tools and combine them with
artificial intelligence and machine learning to potentially block additional types of
fraudulent and scam nuisance calling.

10. We estimate that we carry approximately # calls a month on average on our

network. Based on recent samples, we estimate that # of
these # monthly calls will be blocked under CETRP
2018-484. Of those # calls, we can confirm that at least # or
some # calls are suspicious.

11. Further, fraudsters are already using conforming called ID numbers today. Based on the
same samples, we have identified an additional # Verified Fraud Calls on our
network that use conforming caller ID and thus would not be blocked under CETRP
2018-484.

12. Given that the Commission has already identified universal network-level call blocking as
the most effective and efficient solution to protect Canadians from blatantly illegitimate
calls, we are filing this Part 1 Application to seek Commission approval to conduct a trial
to block Verified Fraud Calls received or transmitted from, to, or over our networks.

III Particulars of this blocking proposal

13. We propose to implement the following call blocking methodology on a trial basis:

a) # 4 





#

b) # 



#
(i) # #
(ii) # #
(iii) # #
(iv) # #
(v) # #
(vi) # #

c) # 





#

d) # #

# Filed in confidence with the CRTC.

4 # 

#
2019 07 24 Abridged 4

e) # 















#

f) # 

#

g) # 













#

h) # 



#

14. Given the nature of the mechanism explained above, this blocking would impact all calls
that transit or terminate on our network (i.e., even a call that originates internationally
and is destined for another local exchange carrier (LEC) that is not our affiliate, but for
which an interexchange carrier delivers the call to us to transit for them to that LEC,
would be blocked based on the above criteria).

IV Timing of Proposal

15. We propose to commence the trial during the latter part of the third quarter or the early
part of the fourth quarter of 2019. The launch date of our trial is not in any way
connected with, or dependent upon, the launch date of universal call blocking in
accordance with CETRP 2018484.

16. We propose to conduct the trial for 90 days. We are committed to sharing on a
confidential basis the following particulars, or such other particulars as the Commission
may request flowing from the trial:

− Number of blocked calls;

− Numbers of individually blocked originating calling line identifications;
− Types of fraudulent or scam calls blocked (by type); and
− Numbers of "false positives" (if any).

# Filed in confidence with the CRTC.

V Law and Regulation

17. Section 36 of the Act states as follows:

2019 07 24 Abridged 5

Except where the Commission approves otherwise, a Canadian carrier shall not
control the content or influence the meaning or purpose of telecommunications
carried by it for the public.

18. In Empowering Canadians to protect themselves from unwanted unsolicited and

illegitimate telecommunications, CETRP 2016-4425 at paragraph 96, the Commission
indicated it would approve universal blocking of "blatantly spoofed calls" under section
36 of the Act once it had received a CRTC Interconnection Steering Committee (CISC)
report on the issue.

19. This Application is consistent with these prior Commission statements on the interpretation
of section 36 of the Act. As with the measures to block "blatantly spoofed calls", under our
methodology, the only fraudulent and scam calls blocked would be those confirmed to be
fraudulent scams # 

#.

20. Approval of this Application would further a number of the Act's objectives, including the
following:

− Section 7(a): it would safeguard, strengthen and enrich the social and economic
fabric of Canada by protecting Canadians against the scourge of telemarketing
fraud;
− Section 7(e): it would promote the use of Canadian transmission facilities and
telecommunications by instilling greater confidence by Canadians in the
telephone ecosystem by reducing confirmed fraudulent and scam calls;
− 7(g): it would stimulate research and development by enabling us to test, and if
necessary, further refine our blocking proposal; and
− 7(i): it would contribute to the privacy of Canadians by reducing an invasive and
harmful form of calling.

21. Our proposed measure is also consistent with the Policy Direction 6. Section 1(b)(iv) of
the Policy Direction prescribes that when the Commission is relying on regulation, in the
case of measures relating to network interconnection, it should ensure technological and
competitive neutrality. This measure applies equally to traffic regardless of the network
of origination or termination. Our proposed measure is also consistent with many of the
directions in the Order Issuing a Direction to the CRTC on implementing the Canadian
Telecommunications Policy Objectives to Promote Competition, Affordability, Consumer
Interests and Innovation7. For example, by approving our proposal herein, the
Commission would be acting in furtherance of the following objectives:

− Section 1(a)(iii) improving upon the already high quality of Canadian

telecommunications;
− Section 1(a)(iv): enhancing and protecting the rights of consumers;

# Filed in confidence with the CRTC.

− Section 1(a)(vi): fostering innovation, including new technologies and
differentiated service offerings; and
− Section 1(a)(vii): stimulating investment in research and development.

5 Compliance and Enforcement and Telecom Regulatory Policy CRTC 2016-442, Empowering Canadians to
protect themselves from unwanted unsolicited and illegitimate telecommunications.
6 SOR/2006-355, Order Issuing a Direction to the CRTC on Implementing the Canadian Telecommunications
Policy Objectives, 14 December 2006 (the 2006 Policy Direction).

7 Please see: http://www.gazette.gc.ca/rp-pr/p1/2019/2019-03-09/html/reg5-eng.html (the 2019 Policy Direction).

2019 07 24 Abridged 6

22. For all of these reasons we respectfully request a Commission order allowing us to
conduct the aforementioned trial using the methodologies described above, with such
modifications as the Commission considers just and reasonable in the circumstances.

Yours truly,

[ Original signed by P. Gauvin ]

Philippe Gauvin
Assistant General Counsel

Attachment

c.c.: CLECs, ILECs, SILECs, Other Carriers and Wireless Carriers

*** End of Document ***