Final Submission : Yellow Pages Limited (Intervenor 755)

Document Name: 2015-134.227335.2613786.Final Submission (1k0t601!).pdf

Final Submission : Yellow Pages Limited (Intervenor 755)

Document Name: 2015-134.227335.2613788.Final Submission (1k0t801!).html

Raisons pour comparaitre / Reasons for appearanceYellow Pages Limited ("YP") requests to appear at any future hearing in order to provide input regarding the CRTC's review of the basic service objective, and in particular the entitlement of Canadians to receive a printed copy of the current local telephone directory upon request.As a Canadian search media provider and directory publisher, YP has an in interest in the future of telephone directories and is well placed to provide insight into market trends and consumer demand in this area. YP believes its appearance at any future public hearing is necessary in order to provide important and unique additional input to the CRTC beyond its written statement and to respond to any additional concerns related to directory matters raised by other interveners at this later stage of the consultation process.

Final Submission : Yellow Pages Limited (Intervenor 755)

Document Name: 2015-134.227335.2613787.Final Submission (1k0t701!).pdf
Telecom Notice of Consultation CRTC 2015-134
Review of Basic Telecommunications Services
Final Submission of Yellow Pages Limited
May 25, 2016

http://www.google.ca/url?sa=i&rct=j&q=&esrc=s&source=images&cd=&cad=rja&uact=8&ved=0ahUKEwjfm8f7td7KAhVDgj4KHdMKC8MQjRwIBw&url=http://www.newswire.ca/news-releases/yellow-pages-now-provides-business-data-to-apple-for-local-search-in-canada-534071441.html&bvm=bv.113370389,d.dmo&psig=AFQjCNFn9bOt7E4G5CoDEB0hlDywVqp7JA&ust=1454686048445637Yellow Pages Limited **** 2 of 15

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TABLE OF CONTENTS

EXECUTIVE SUMMARY .................................................................................................................. 3 I. CLARIFYING THE REGULATORY FRAMEWORK ....................................................................... 4 II. MAINTAINING A REGULATORY FRAMEWORK .......................................................................... 6 III. UPDATING THE REGULATORY FRAMEWORK .......................................................................... 8 a. Print requirements are out of step with today’s environment and the goals of the Consultation .... 8 b. Previous regulatory changes demonstrate that Canadians are ready for the next step ...............10 c. Digital is beneficial .................................................................................................................12 d. On-demand print distribution requirements are not sustainable ................................................13 e. A phase-out approach may be adopted ...................................................................................13 f. Discussions regarding wireless numbers are premature ...........................................................14 IV. CONCLUSION ...........................................................................................................................14 Yellow Pages Limited **** 3 of 15

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EXECUTIVE SUMMARY

1. Yellow Pages Limited (“YP”) is pleased to file this Final Submission in the Review of Basic Telecommunications Services consultation proceeding (the “Consultation”) initiated by the CRTC on **** 9, 2015 pursuant to Telecom Notice of Consultation CRTC 2015-134 (“TNC 2015-134” or the “Notice”).

2. YP has chosen to provide comments and appear at the hearing for the Consultation given its role as Canada’s largest directory publisher and as a leading media and marketing solutions provider. YP has in-depth knowledge regarding the evolution of the telephone directory publication and distribution framework in Canada, which is a component of the basic service objective being reviewed by the CRTC as part of the Consultation.

3. As outlined in our earlier comments and in our presentation at the hearing, YP recommends that the CRTC maintain an entitlement for Canadians to receive access to a local telephone directory as part of the basic service objective, but that the form requirement of such directory be changed to a digital format. More specifically, YP recommends that all CRTC-mandated requirements specifying the distribution of paper-printed telephone directories be replaced by an obligation to continue to provide access to listings, but via digital platforms and means only.

4. The stated goal of the Consultation is to examine which telecommunications services are required by Canadians to participate meaningfully in the digital economy. Following certain comments made by the CRTC during the hearing, it is clear that the focus of this Consultation has shifted towards the development and implementation of a broadband strategy for Canada.

5. Given the more pressing issues at play in the Consultation, very few parties turned their attention to directory distribution requirements in their submissions or in their appearances at the hearing. Paper-printed directories are simply not seen as being important to Canadians.

Nevertheless, the few discussions surrounding directory matters which have taken place to date have demonstrated some confusion in understanding the current regulatory framework applicable to the provision of paper-printed directories. There also appears to be an apprehension to modernize the directory framework, which may either be based on the fact that directory matters are not at the forefront of the Consultation, or the fact that parties often have an incomplete understanding of the evolution and current state of the regulatory framework applicable to telephone directories, as well as related market trends in this area.

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6. YP believes that directory distribution requirements should not be disassociated from the purpose of the Consultation and the development of a national broadband strategy. Instead, directory distribution requirements should be modernized to reflect the realities and needs of Canadians in today’s digital economy and be folded into efforts to deploy affordable broadband Internet access across all Canadian regions. YP recommends a shift towards the digital-only publication of directory listings, as this change supports the goals of this Consultation by ensuring that Canadians remain connected to one another and their local communities through digital means.

7. Accordingly, YP wishes to reiterate as part of this Final Submission that the regulatory framework applicable to the provision of paper-printed directories:

- should be clarified, given the complexities surrounding the framework highlighted in the document filed by YP in response to an undertaking;

- should remain regulated, given the continued importance of complete listing information;

and

- should be modernized to reflect the realities of Canadians today and in the years to come.

I. CLARIFYING THE REGULATORY FRAMEWORK

8. It is first important to grasp certain complexities of the regulatory framework applicable to the provision of paper-printed directories in order to understand the scope of this Consultation as well as the scope of YP’s recommendation.

9. The CRTC is currently engaged in a review of the basic service objective, a component of which involves the provision of telephone directories to customers. In particular, paragraph 14 of the Notice issued by the CRTC in connection the Consultation states that the basic service objective, applicable in non-forborne exchanges, includes a requirement for Incumbent Local Exchange Carriers (“ILECs”) to provide customers “a printed copy of the current local telephone directory upon request.”

10. During the question and answer period following YP’s appearance at the hearing in connection with the Consultation on **** 20, 2016, the CRTC explained its understanding that all Yellow Pages Limited **** 5 of 15

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local directories, including both residential directories (commonly referred to as the “white pages”)1

and business directories (commonly referred to as the “yellow pages”)2

, are required to be made

available upon request in non-forborne exchanges pursuant to the basic service objective.

11. However, as a directory publisher who has dealt with the regulatory framework applicable to the provision of paper-printed directories through several decades, YP recognizes that such framework is highly complex. YP also recognizes that the statement included in the Notice to the effect that ILECs are required to provide “a printed copy of the current local telephone directory upon request” to their customers in non-forborne exchanges does not represent an accurate summary of the regulatory framework applicable to all types of directories distributed across Canada.

12. Accordingly, at the hearing, the CRTC requested that YP undertake to summarize its understanding of the regulatory framework applicable to the provision of telephone directories. YP’s response to this undertaking was submitted on May 5, 2016 and is part of the public record of this proceeding.

13. While YP’s response to the undertaking details the various CRTC decisions and policies that govern the provision of telephone directories to this day, it is important to note that the CRTC’s most recent decision concerning the basic service objective

3
changed the distribution framework in non-

forborne exchanges to an “upon request” model for paper-printed residential directories only, while paper-printed business directories in non-forborne exchanges continue to be subject to a requirement of mass distribution. This decision did not otherwise impose a broader requirement to distribute all types of directories (or “local directories”) upon request in non-forborne exchanges.

There are also continuing obligations to distribute paper-printed residential directories upon request and to mass distribute paper-printed business directories in forborne exchanges. The directory obligations applicable in forborne exchanges are independent from the basic service objective and are instead based on certain conditions of forbearance established by the CRTC several years ago.

4

The regulatory framework applicable to the provision of paper-printed directories in Canada can therefore be summarized as follows:

1 Residential directories are traditionally printed on white paper and contain basic residential listings in alphabetical order.

2 Business directories are traditionally printed mostly on yellow paper and contain classified business listings and advertisements, followed by basic business listings in alphabetical order. YP also produces combined directories, which contain classified business listings and advertisements, as well as both business and residential listings in alphabetical order.

3 Telecom Regulatory Policy CRTC 2011-291 (Obligation to serve and other matters), issued on May 3, 2011.

4 Telecom Decision CRTC 2006-15 (Forbearance from the regulation of retail local exchange services), issued on **** 6, 2006, as modified by the Governor in Council in Order in Council P.C. 2007-532.

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Table 1: Summary of regulatory framework applicable to the provision of paper-printed directories in Canada

Forborne Exchanges Non-forborne Exchanges

Residential directories Distribution upon request only Distribution upon request only Business directories Mass distribution Mass distribution

14. In light of the wording of the Notice (namely that in non-forborne exchanges, ILECs must provide customers with “a printed copy of the current local telephone directory upon request”), it is YP’s understanding that the scope of this Consultation is limited to the distribution of paper-printed residential directories as part of the basic service objective. The CRTC has never, to YP’s knowledge, made formal changes to the requirement to mass distribute paper-printed business directories in the context of its review of the basic service objective in non-forborne exchanges.

15. Given the complexities highlighted above and in YP’s response to the undertaking, YP encourages the CRTC to expand its review of directory-related obligations in this Consultation in order to clarify the regulatory framework applicable to telephone directories as a whole. The CRTC should generally ensure that the regulatory framework applicable to directories is consistent across all exchanges and across all types of directories that are subject to regulation by the CRTC.

II. MAINTAINING A REGULATORY FRAMEWORK

16. While the regulatory framework discussed above ultimately mandates the provision of paper-printed directories to Canadians, the overall structure of the regulatory framework also includes many additional requirements that ensure such directories contain complete and accurate local listing information.

17. These requirements include an obligation for Competitive Local Exchange Carriers (“CLECs”) to share listing information with ILECs for the purpose of ensuring that complete listing information is made available to Canadians.

5
This specific obligation was introduced by the CRTC in

1997 to counteract issues of potential fragmentation of listing information which arose as competition was introduced in the local telecommunications market.

5 Telecom Decision CRTC 97-8 (Local competition), issued on May 1, 1997.

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18. Through the course of this Consultation, YP has maintained that the regulatory requirements mandating the production of paper-printed directories no longer reflect today’s reality; however, other aspects of the regulatory framework, namely those which require the collection and distribution of complete listing information, remain vital to Canadians. In sum, complete, validated and easily accessible information, facilitated by a regulatory framework, keeps Canadians connected to each other and to their local communities. The regulatory framework is also important to the survival of small and medium-sized businesses, by guaranteeing such businesses a basic form of visibility in the marketplace. In today’s digital economy, however, the regulatory framework should be adapted to new digital realities:

**** businesses are continuously challenged, at a very basic level, by the changing digital environment. Ensuring access to free basic listings in a digital format will help small businesses, at minimum, have a footprint in digital environments upon they can build a larger presence to attract customers. The regulation of the collection and distribution of listing information is in the best interests of all Canadians, as well as the small businesses who are the lifeblood of our communities. The basic listing is a foundational piece of information for communication and interconnectivity that also places Canadian interests first in a globalized environment. However, it should be adapted to reflect the most common format used for communication today, which is digital.

- John Kiru, Executive Director of the Toronto Association of Business Improvement Areas (email to YP on **** 13, 2016)

“The ability to connect with consumers is a critical component of every business.

The existing CRTC legislation – in place for many decades – requires that every business number be listed in a printed directory and made available everywhere in Canada. In the 21st century, the need for businesses to connect with consumers remains the same, but how consumers and businesses connect is mostly digital.

The Ontario Chamber of Commerce (OCC) supports Yellow Pages efforts to update the CRTC legislation to require that all business listings be published digitally across Canada (rather than print). A mandatory, basic digital listing is the first step for any business to be able to connect with consumers in the digital world. This connects with the OCC’s commitments to foster innovation and to help businesses take advantage of new opportunities in the global economy.”

- **** O’Dette, President and Chief Executive ****, Ontario
Chamber of Commerce (email to YP on **** 12, 2016)

19. The regulatory requirements which require the collection and distribution of complete local listing information remain equally essential to the provision of directory listings through digital platforms. Given the overabundance of information with questionable reliability available online, Canadians need to have continued access to validated, complete and trustworthy information. The convenience, usefulness and reliability of many online search tools and applications used to access Yellow Pages Limited **** 8 of 15

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listing information, including Canada 411, depend on a regulatory framework which ensures that complete local listings are shared amongst telecommunications service providers and made available to Canadians.

20. It is also critical that the collection and distribution processes for listing information remain regulated so that such processes are not left only to market forces which may disregard the best interests of Canadian businesses seeking to gain visibility. Larger global players in the digital economy may not be incentivized to promote the public policy of providing visibility to Canadian businesses. If a regulatory framework did not exist, the visibility of Canadian businesses (and in particular small and medium-sized businesses) may be disregarded in favour of international competitors that receive the most exposure to consumers via digital search tools due to an established algorithm which was not built with Canadian interests in mind. A limited regulatory framework in which basic business listing information must be disseminated through digital platforms and means only would ensure the continued visibility of Canadian businesses.

21. It is important to note that participants in the Consultation have not questioned the importance of the regulatory framework in ensuring that complete and accurate listing information is collected and made available to Canadians. Any changes to the requirements that relate to the sharing of listing information amongst telecommunications service providers may have unintended or adverse consequences on the information ultimately made available to Canadians. The CRTC should approach any such changes with caution.

III. UPDATING THE REGULATORY FRAMEWORK

a. Print requirements are out of step with today’s environment and the goals of the Consultation

22. While a regulatory framework governing the provision directory listing information remains critical, YP believes that this framework must be modernized to meet the needs of businesses and consumers today; this was detailed in YP’s earlier comments and presentation at the hearing. The change requested by YP is not a radical one – YP simply recommends that the regulatory framework applicable to directories remain in place, but that the medium for listing information be changed from print to digital.

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23. Such changes were anticipated by the CRTC in its decision establishing the basic service objective in 1999.

6

In this decision, the CRTC stated that the basic service objective should evolve in concert with technological trends. In particular, paragraph 25 of this decision states that “the basic service objective is independent of the technology used to provide service, and may change over time as service expectations evolve.” Given that the regulatory framework governing the provision of paper-printed directories is outdated, it is now time for this change to occur.

24. The Consultation, which is aimed at examining the telecommunications services Canadians require to participate meaningfully in today’s digital economy, represents an ideal opportunity for the CRTC to revisit its directory distribution policies in light of current market needs. Given that the CRTC has shifted the focus of the Consultation to the development of a national broadband strategy, the CRTC’s directory distribution policies should also reflect the fact that as a result of the Consultation, regulatory policies will also be adopted with the goal of ensuring that individuals across Canada (including in rural and remote areas) are increasingly able to access affordable and reliable Internet services. Simply put, directory issues must be examined through the national broadband strategy lens. A shift towards the digital-only publication of directory listing information supports the goals of this Consultation, by ensuring Canadians remain connected to one another and their local communities through digital means today and following the future deployment of a national broadband strategy.

25. If the CRTC decides to maintain a framework requiring the provision of paper-printed directories, it will be preserving an outdated framework that is and would henceforth remain out of step with the needs of Canadians. As noted by the CRTC in its 2015 Communications Monitoring Report, fixed and mobile broadband services are already available to over 99% of households in Canada through the deployment of various technologies.

7
The 2015 Communications Monitoring

Report also confirms that Canadians have shifted the way they use their mobile devices, and now place greater emphasis on data services (rather than voice services) to access mobile applications, Internet browsing and other data driven services.

8
These data intensive activities have driven

wireless data growth to over 14.9% in 2014, and, on average, 22.4% over the past five years.

9

Together, these data points confirm that almost all Canadians currently have the ability to access digital listings using a variety of devices that can connect to the Internet via both landline and 6 Telecom Decision CRTC 99-16 (“Telephone Service to High-cost Serving Areas”), issued on October 19, 1999.

7

CRTC, 2015 Communications Monitoring Report, published in October 2015, pp. 187 and 202.

8
Ibid at p. 220.
9
Ibid.
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wireless means. Furthermore, access to digital listings (including listings made available through YP’s digital services and mobile applications) does not require a particularly high-speed connection.

Simply put, digital listings are readily accessible to and favoured by Canadians. Such access will continue to be further enhanced in the future.

26. As mentioned repeatedly by both the CRTC and other participants during the hearing10

, the

regulations which will be adopted as a result of the Consultation should not only ensure that Canada is prepared for today’s realities, but also for the future. A CRTC decision requiring the continued publication and distribution of paper-printed directories risks becoming quickly stale-dated in light of the rapid growth in popularity of digital applications and the future deployment of a national broadband strategy.

b. Previous regulatory changes demonstrate that Canadians are ready for the next step

27. It is also relevant to note that previous regulatory changes to the directory distribution requirements which have led to reductions in the distribution of paper-printed directories have been successful as opposed to disruptive, signaling that Canadians are ready for the changes proposed by YP.

28. Following a noticeable decline in print directory usage in the early 2000s, YP shifted the distribution model for its paper-printed residential directories in major cities across Canada to a biennial delivery schedule, with residents needing to request delivery in the off-year.

11
Data tracking

the resulting demand in the years that followed showed fewer than 2% of addresses requested a directory in the off-year.

29. In 2010, following the continued decline in usage of paper-printed directories and the rapid increase in access to listing information through digital platforms, YP requested that the CRTC approve YP’s on-demand distribution model for paper-printed residential directories in certain large urban markets. After studying the matter, the CRTC agreed that YP’s distribution policy would be 10 See for example comments of Commissioner Venard in Consultation transcript volume 8 (April 20, 2016), line 10039, as well as comments of Commissioner **** in Consultation transcript volume 12 (April 26, 2016), line 16053.

11 See exchanges between the CRTC and Bell (CRTC File No: 8000-B2-01/03, including Commission Letter dated May 11, 2007) and exchanges between the CRTC and Telus (CRTC File No: 8665-T66-200806599, including Commission Letter dated November 24, 2008). In both cases, the CRTC approved biannual distribution plans for residential directories (the “white pages”), subject to certain conditions and safeguard measures.

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appropriate.
12

The CRTC later adopted this same distribution policy for the distribution or paper-printed residential directories in non-forborne exchanges in the most recent decision concerning the basic service objective (issued in 2011).

13

30. YP has also noticed a decline in the usage of paper-printed business directories. As a result, in 2009, YP introduced a system allowing Canadians to remove their address from the business directory distribution list. In 2015, as part of a concerted effort to address individual market needs, YP altered its distribution model to a more targeted approach. This involved the heavy analysis of consumer market data, specific to each Canadian community, to identify select neighbourhoods or even streets across Canada that have high concentrations of consumers who do not make use of paper-printed business directories. In these regions, automatic door-to-door delivery subsequently ceased, and was replaced by a combination of pick-up locations and other means.

31. The historical changes listed above demonstrate YP’s in-depth understanding of consumer trends and requirements for local listing information. YP has always made it a priority to bring these trends and requirements to the CRTC’s attention in order to ensure that the regulatory framework applicable to directories and listing information is routinely realigned to reflect the needs of Canadians.

32. Notwithstanding these efforts, the current regulatory framework is once again out of step with the search habits and preferences of Canadians in today’s digital economy, as witnessed firsthand by YP. Given their widespread preferences for digital platforms, Canadians now require further changes to the framework applicable to directories and listing information.

33. Even the Canadian government has recognized that the directory framework is out of date. In late 2014, the Shared Services department of the Federal Government sent a letter to YP explaining that it no longer wished to provide government numbers for inclusion in the **** Pages, the section historically listing all government numbers in paper-printed directories. Federal government contact information is now accessible online, illustrating that the government is realigning itself with Canadian market trends.

12 Letter from John Traversy, Executive Director-CRTC, to **** Ramsay, Senior Vice-President, General Counsel and Secretary, YP dated **** 2, 2010.

13 Telecom Regulatory Policy CRTC 2011-291 (Obligation to serve and other matters), issued on May 3, 2011.

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c. Digital is beneficial

34. Maintaining the obligation to print directories as part of the regulatory framework would create unnecessary waste and also potentially deprive Canadians of the benefits of complete digital listings.

35. Digital technologies provide important access opportunities for individuals with certain disabilities, including individuals who are visually impaired. Digital listings are therefore more accessible to a wide range of Canadians as compared with traditional paper-printed listings. As outlined by representatives of Media Access Canada during its presentation at the hearing, “advanced mobile services offer a new world of access to the outside world and possibilities for social and economic interactions previously unimaginable to persons with disabilities”.

14

Representatives from Media Access Canada also noted that “over the last decade, a wide range of internet applications have evolved that can enhance the quality of life and opportunities’ for persons with various types of disability”.

15

Digital listings can be fed into these applications and platforms to enhance access opportunities.

36. Furthermore, paper-printed directories quickly become stale-dated, whereas digital listings are more accurate as they are updated with much greater frequency (e.g. monthly). Digital listings are also available on computers as well as on a range of mobile devices, and can be accessed rapidly from almost any location. These benefits are relevant to individuals in rural and remote areas, given the delays associated with the physical delivery of paper-printed directories in these locations and the frequency at which listing information may change. For instance, the lag time between the collection of directory data and the eventual publication and distribution of paper-printed directories is approximately 14 months. Such paper-printed directories thereafter remain in place for a 12-month period.

37. Participants in the Consultation have also commented that Canadians are not limited to transacting within their geographical area. This is especially true in more remote regions where local information is widely known and where broader listing information (encompassing neighboring regions) would be more relevant and useful for the population.

16
Having a digital, Canada-wide

14 Consultation transcript, volume 6 (April 18, 2016), line 7224.

15 Consultation transcript, volume 6 (April 18, 2016), line 7231.

16 A similar comment was made by the First Mile Connectivity Consortium (Consultation transcript, volume 1 (April 11, 2016), line 750-752).

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directory is much more useful and practical than having stale-dated regional phonebooks which no longer reflect the community in which Canadians transact.

d. On-demand print distribution requirements are not sustainable 38. Reduced distribution models for paper-printed directories (including on-demand directory distribution models) are simply not sustainable going forward given the efforts, costs and environmental concerns related to the production and delivery of even a small number of paper-printed directories.

39. Maintaining a requirement to distribute paper-printed directories upon request would cause the expenditure of disproportionate costs and efforts as compared with the need for printed directories today. Regulatory policies should ensure that a rational balance is struck between the low usage of paper-printed directories and the impact that print distribution requirements will have on the business practices of certain entities involved in the directory publication and distribution process.

e. A phase-out approach may be adopted

40. YP understands that the CRTC and certain other participants in the Consultation are concerned about the lack of adoption of broadband in certain Canadian regions and the fact that digital-only listings may therefore not be accessible to all.

41. YP considers that broadband availability rates are already extremely high, that the affordability and quality of broadband services will only continue to increase in accordance with the goals of this Consultation, and that digital listings are in many ways more accessible than paper-printed listing information (as outlined above). Nevertheless, should the CRTC be unwilling to adopt a Canada-wide, digital-only directory distribution strategy on the basis that the current timing is not appropriate, YP recommends a phase-out strategy for the distribution of paper-printed directories in certain specific regions.

42. This phase-out strategy would involve printing a limited number of residential and business directories for distribution in non-forborne exchanges (i.e. exchanges which are subject to the basic service objective as currently drafted) for the next three (3) years. During this three (3) year period, paper-printed residential directories would continue to be distributed on an on-demand basis in non-forborne exchanges, while paper-printed business directories would continue to be mass-distributed through drop-box distribution methods (i.e. pre-determined locations from which Canadians may Yellow Pages Limited **** 14 of 15

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retrieve paper-printed directories) in non-forborne exchanges. After this three (3) year period, all regulatory requirements specifying the distribution of paper-printed directories in non-forborne markets would be replaced by an obligation to continue to provide access to listings, but via digital platforms and means only.

43. The three (3) year phase-out strategy for paper-printed directories described above would apply only in the non-forborne exchanges, while the digital-only strategy for directory distribution recommended by YP would be immediately implemented in forborne exchanges for all types of directories (both residential and business).

f. Discussions regarding wireless numbers are premature

44. As stated in the CRTC’s 2015 Communications Monitoring Report, approximately 20% of Canadian households subscribe exclusively to mobile wireless telephone services.

17
During YP’s

appearance at the hearing, the CRTC asked YP to comment on the fact that an increasing number of Canadians are using mobile devices, yet wireless listings are not included in telephone directories.

45. YP is of the view that until the adoption of mobile devices as exclusive devices for telephone services in Canada reaches a much higher threshold, YP cannot pronounce itself on the inclusion of wireless listings in directories as there its simply does not have enough information available to adequately address this matter. Accordingly, YP has no further comment on the inclusion of wireless listings in directories at this time.

IV. CONCLUSION

46. YP has appreciated the opportunity to participate in the Consultation and shares the CRTC’s commitment to ensuring Canadians have access to the services they need to meaningfully participate in Canada's digital economy.

47. While directory distribution requirements have received little attention from parties in the Consultation, YP wishes to stress that such requirements:

17 CRTC, 2015 Communications Monitoring Report, published in October 2015, pp. 1, 9, 18 and 20).

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- should be clarified, given the complexities surrounding the framework highlighted in the document filed by YP in response to an undertaking;

- should remain regulated, given the continued importance of complete listing information;

and

- should be modernized to reflect the realities of Canadians today and in the years to come.

48. More specifically, YP recommends that the regulatory framework applicable to telephone directories remain in place, but that a one-size-fits-all approach be applied to all directories whereby all CRTC-mandated requirements specifying the distribution of paper-printed directories be replaced by an obligation to continue to provide access to listings, but via digital platforms and means only.

YP believes this recommendation to be in line with the stated objectives of the Consultation, as well as the values of Canadian consumers and businesses participating in today’s digital economy. A shift towards the digital-only publication of directory listings supports the goals of this Consultation, by ensuring that Canadians remain connected to one another and their local communities through digital means.

* * * End of document * * *