Telecom Decision CRTC 2003-65

Ottawa, 29 September 2003

Northwestel Inc. - Application to remove the joint marketing restrictions

Reference: 8622-N1-200301359

In this decision, the Commission approves the application filed by Northwestel Inc. (Northwestel) to remove the prohibitions against Northwestel jointly marketing its services with those of its wireless affiliate, Northwestel Mobility Inc. In addition, the Commission provides its preliminary views on having Northwestel comply with the Commission's bundling and affiliate rules and with its views with respect to the regulation of Canadian carriers under common control with an incumbent local exchange carrier. A show cause process is established to assess the appropriateness of implementing the Commission's preliminary views.


1. The Commission received an application filed pursuant to Part VII of the CRTC Telecommunications Rules of Procedure, dated 5 February 2003, from Northwestel Inc. (Northwestel) requesting that the Commission remove the prohibitions which prevent Northwestel from jointly marketing its services with those of its wireless affiliate, Northwestel Mobility Inc. (NMI). NMI provides cellular services in Northwestel's service territory.

2. The Commission received comments from the Yukon Government (YG) dated 20 February 2003 and 21 March 2003, the Yellowknife Chamber of Commerce (YKCC) dated 28 February 2003, the Whitehorse Chamber of Commerce (WCC) dated 10 March 2003, the Utilities Consumers' Group (UCG) dated 18 March 2003, the New North Networks Ltd. (NNN) dated 26 March 2003 and from the Yukon Chamber of Commerce (YCC) dated 2 April 2003. Northwestel submitted reply comments dated 2 April 2003.


3. In Cellular Radio - Adequacy of structural safeguards, Telecom Decision CRTC 87-13, 23 September 1987 (Decision 87-13), the Commission imposed joint marketing restrictions on the incumbent local exchange carriers (ILECs) in order to facilitate competitive entry into the then newly emerging market for mobile wireless telecommunications services. These restrictions were reiterated in Rogers Cantel Inc. v. Bell Canada - Marketing of cellular service, Telecom Decision CRTC 92-13, 29 June 1992 (Decision 92-13).

4. In accordance with a Commission letter dated 14 February 1997, Northwestel implemented, on 1 May 1997, the joint marketing restrictions stipulated in Regulation of mobile wireless telecommunications services, Telecom Decision CRTC 96-14, 23 December 1996 (Decision 96-14). In Decision 96-14, the Commission found it appropriate to extend the prohibitions from the above-noted decisions to relations of the telephone companies with affiliates providing any public switched mobile voice services.

5. In Review of joint marketing restrictions, Telecom Public Notice CRTC 97-14, 25 April 1997 (Public Notice 97-14), the Commission noted that the joint marketing restrictions, established in Decisions 87-13 and 92-13, were a series of safeguards designed to prevent a wireline telephone company from conferring on itself or its cellular affiliate an undue preference or advantage, contrary to subsection 27(2) of the Telecommunications Act. The established safeguards included:

  1. a prohibition on joint marketing and advertising;
  2. a requirement for neutral customer referrals;
  3. a prohibition on the exchange of confidential customer information; and
  4. a prohibition on the cross-subsidization of cellular services by wireline services.

The Commission, in Public Notice 97-14, sought comments on whether, in light of developments in the marketplace, it was appropriate to continue to impose on the former Stentor Resource Centre Inc. (Stentor) companies and independent telephone companies the joint marketing restrictions noted above.

6. In Review of bundling and joint marketing restrictions, Telecom Public Notice CRTC 97-21, 6 June 1997 (Public Notice 97-21), the Commission announced that it was expanding the scope of the proceeding established in Public Notice 97-14 to include consideration of bundling issues and sought comments on the bundling of a tariffed service with:

7. The Commission also stated, in Public Notice 97-21, that it did not intend to reconsider issues concerning the bundling of telecommunications services provided in-house by the former Stentor companies. Issues concerning such bundling were addressed in Review of regulatory framework, Telecom Decision CRTC 94-19, 16 September 1994 (Decision 94-19) and Local competition, Telecom Decision CRTC 97-8, 1 May 1997 (Decision 97-8).

8. Pursuant to the proceedings initiated by Public Notices 97-14 and 97-21, Joint marketing and bundling, Telecom Decision CRTC 98-4, 24 March 1998 (Decision 98-4) was issued. In that decision, the Commission removed the prohibition against joint marketing of mobile wireless and wireline services for the former Stentor companies and the independent telephone companies. Northwestel was not a party to this proceeding. The Commission also set out, for the former Stentor companies, the rules for the bundling of tariffed telecommunications services with those of an affiliated or a non-affiliated company, or with non-telecommunications services.

9. On 8 March 1999, Northwestel filed an application requesting that the Commission remove the prohibition against the company's joint marketing of wireline and mobile wireless telecommunications services. The Commission denied Northwestel's application in Joint marketing restrictions retained for Northwestel, Order CRTC 2000-396, 12 May 2000 (Order 2000-396). The Commission concluded that:

Northwestel's application

10. Northwestel submitted that there have been a number of significant changes to its telecommunications environment subsequent to the issuance of Order 2000-396. These changes included: the Commission's release of Long-distance competition and improved service for Northwestel customers, Decision CRTC 2000-746, 30 November 2000 (Decision 2000-746), which introduced long distance competition into Northwestel's operating area and established a unique and appropriate regulatory framework for the north; and a rapid growth of wireless competition in the company's wireless affiliate's most profitable areas, especially by large southern-based service providers.

11. Northwestel submitted that the Commission's overall objective of the introduction of long distance competition in Decision 2000-746 was to promote rational competition that fits the unique characteristics of the north while providing customers with reasonably comparable services at reasonably comparable rates. Northwestel suggested that removing the joint marketing restrictions would not only enhance the company's ability to meet these customer requirements but would also enable Northwestel to take the necessary measures to improve efficiencies, thereby minimizing the requirement for supplementary funding.

12. Northwestel submitted that the barriers to competitive entry with respect to the long distance market, which the Commission determined in Order 2000-396, were one of the major reasons why the company was not permitted to remove the joint marketing restrictions at the time, have now been eliminated and northerners should now be able to enjoy the benefits of joint marketing.

13. In support of its application, Northwestel submitted that the Commission had recognized in Decision 98-4 that joint marketing between affiliated companies had definite consumer and industry advantages. In particular, Northwestel noted the Commission's statements that joint marketing would better satisfy consumer demand for one-stop shopping and integrated services, and lead to a more cost-effective provisioning of telecommunications services.

14. Northwestel further indicated that the Commission recognized in Order 2000-396 that these benefits of joint marketing also pertained to Northwestel's operating territory. Northwestel submitted, however, that while the Commission had recognized the benefits of joint marketing, the Commission's major concern at the time of Order 2000-396 was that there was no effective competition in Northwestel's territory, concluding that the benefits of joint marketing in Northwestel's territory were not sufficient to offset the negative effects on the development of competitive markets.

15. With respect to the degree of long distance competition in its territory, Northwestel submitted that prior to 2001, its long distance market share had been eroded by the resale of long distance service by the federal government. Northwestel indicated that this resale continued until August 2002 after which the related traffic was switched to a large national provider which was awarded the national Government Telecommunications Informatics Systems contract in late 2001. Northwestel submitted that this equal access competitor has so far targeted high-volume customers in the larger centres, as would be expected in the early stages of competition. Northwestel indicated, however, that it anticipated this competitor would target the equal access markets of Whitehorse, Yellowknife and Fort Nelson in 2003. Northwestel further indicated that this competitor is one of the largest wireline and wireless companies in Canada and anticipated that this company would offer bundled wireline and wireless services to the largest business and government customers. Northwestel also pointed out that another equal access provider has recently entered its operating territory, and that a third such party has had discussions with the company.

16. Northwestel submitted that another significant change since the issuance of Order 2000-396 related to the current market conditions in the north under which wireless services were provided. Northwestel submitted that wireless service providers (WSPs) now offer comprehensive services that compete as substitutes to local and long distance wireline services and emphasized that these competitors generally base their prices on their national costs, rather than on the specific costs incurred in their northern market. Northwestel submitted that new competitor facilities allow WSPs to offer comprehensive telecommunications service packages in the north's "high-valued" markets.

17. Northwestel submitted that TELUS Communications Inc. (TCI) has extended a high speed-digital-microwave network into NMI's most active service area, northeastern British Columbia, where oil and gas exploration was the pre-eminent business. Northwestel further submitted that this would also allow TCI to compete with Northwestel in wireline services. In addition, Northwestel pointed out that TCI operated a number of private networks in northern British Columbia with a range of voice and data services, making TCI a full service provider, offering comprehensive packages at non-tariffed terms and conditions to certain targeted customers.

18. Northwestel further submitted that new competitors have other regulatory advantages in that they could cross-subsidize to seize further market share, and they were not required to file tariffs. Northwestel suggested that these regulatory advantages, along with name brand recognition, help its competitors to price Northwestel out of many of its best "high-valued" markets, as regulation restricts Northwestel's ability to offer comprehensive packaged communication services. Northwestel argued that it must have the ability to meet the interests of "high-valued" customers in remote locations who require fully-integrated packages that include mobile, fixed, long distance, data and Internet services.

19. With respect to local competition, Northwestel noted that the Commission refrained from examining the introduction of local competition at the time of Decision 2000-746. Given the unique nature of the telecommunications market in the north, Northwestel submitted that local wireline competition may never be practical in Northwestel's service territory and that competitor wireless services have already substituted for wireline basic local service in "high-valued" locations. Northwestel, however, argued that the lack of local competition should not be a barrier to prevent the company from providing consumer benefits that relate to the joint marketing and bundling of services.

20. Northwestel suggested that while local competition was not currently permitted, this does not prevent radio and satellite service entrants not subject to the joint marketing restrictions from offering bundles that include private network facilities, cellular mobile radio services, along with long distance services and associated equipment.

21. Northwestel submitted that its customers have expressed frustration over not having the option to deal with one customer service representative (one-stop shopping) and receive one bill for telecommunications services. Northwestel noted, as an example, that customers in the oil and gas industry require quick deployment of multiple integrated services including wide area network configurations linked to home offices and other data requirements, cellular and other mobile radio services, and fixed key systems with local and long distance voice services. Northwestel submitted that customers view these services as being complementary and are confused and disappointed when asked to seek services from several representatives, viewing this as an unnecessary and costly delay, particularly in remote resource development areas.

22. With respect to safeguards against cross-subsidization, Northwestel was of the view that sufficient safeguards are already in place to ensure that competitors are not disadvantaged should the joint marketing restrictions be removed. These safeguards included accounting separation, reporting requirements during annual regulatory proceedings, intercorporate transaction reporting, and annual Phase III reporting.

23. Northwestel submitted that with regard to safeguards against the bundling of services with those of its wireless affiliate, it was of the view that the current restrictions would continue to apply. Northwestel submitted that it would continue to comply with imputation tests on bundled packages including tariffed telephone company services bundled with affiliate services. Northwestel indicated that as the vast majority of services that Northwestel provides are currently tariffed, the Commission would have an opportunity to ensure, on a case-by-case basis through the tariff application process, that no anti-competitive behavior would result.

Parties' comments

24. Comments in support of Northwestel's application were filed by WCC, YCC and YKCC. NNN and UCG opposed Northwestel's request. YG thought it was advisable to consider this application in the context of an overall review of the telecommunications regulatory framework in the north; in YG's view, Northwestel's application addressed just one aspect of competition in telecommunications services, and that a broader view of the opportunities for competition, particularly northern-based competition, was needed.

25. NNN was of the view that Northwestel had failed to make the case that substantive changes to the competitive environment have taken place in its operating territory since the issuance of Order 2000-396 and that its request to have the joint marketing restrictions lifted should not be granted.

26. With respect to Northwestel's claim that the barriers to entry in long distance competition have now been removed, NNN was of the view that, while there has been some competitive entry in Northwestel's territory, this was just one step towards the start of competition as other forms of wireline competition, such as local wireline, are still precluded. NNN submitted that Northwestel should not be granted any relaxation in the joint marketing restrictions until the telecommunications market was further opened to competition and, in particular, until local wireline competition was at least permitted.

27. NNN indicated that neither TELUS Mobility Inc. nor the radio and satellite service providers can become significant competitors to Northwestel since they were prevented, under the current regulatory regime, from offering the local services that can only be offered by Northwestel. NNN argued that most of the small northern-owned companies who offer competitive telecommunications services were in competition with Northwestel because it was unable, or unwilling, to provide the services when required, and in fact often entered the market only after such services were pioneered and initially developed.

28. NNN acknowledged there was a demand by some customers for one-stop shopping of a range of telecommunications services both to aid efficiencies and timeliness of service as pointed out by Northwestel. NNN also agreed with Northwestel that an ability to jointly market its products and services was definitely a key customer benefit.

29. However, NNN submitted that it and its partners are the primary supplier of communications services in the Mackenzie Delta oil patch area and that it knows from talking to its customers that customers would also be opposed to a constriction of competition for a possible reduction in the amount of subsidy received by Northwestel. According to NNN, if Northwestel received the lifting of the restrictions it requested, Northwestel would be the only choice as an integrated service provider.

30. NNN disagreed with Northwestel's statements that removal of the joint marketing restrictions would ensure equity of regulatory treatment, provide a more level competitive playing field and foster competitive equality between the small incumbent and the large competitive entrants. NNN suggested that the removal of the joint marketing restrictions would simply reinforce Northwestel's dominant position and do nothing to stimulate or even support competition.

31. UCG submitted that it was not convinced that Northwestel had proven that the benefits of removing the joint marketing restrictions will outweigh the negatives. UCG was of the view that the north has a very vulnerable market for business operations, especially for home-grown businesses such as those in the Internet and cable markets, as the north's population base was so limited and spread over a large landmass. UCG stressed that the Internet and cable are niche markets for northern entrepreneurs, bringing them much needed local employment and investment, and emphasized that these niche markets have steadily experienced erosion due to competition by Northwestel affiliates. UCG argued that allowing joint marketing and bundling for Northwestel could place these small independent competitors at further risk of being driven out of the market.

32. YKCC was of the view that removal of the joint marketing restrictions would increase competition in the Yellowknife market area and would likely bring benefits to Yellowknife businesses and residents in the form of increased consumer choice, reduced telecommunications costs, enhanced services, and a possible increase to local employment. YKCC further emphasized that with the removal of the barriers to competitive entry in Yellowknife's long distance market on 1 January 2001, the joint marketing restrictions were no longer required.

33. In supporting Northwestel's application to remove its joint marketing restrictions, WCC and YCC indicated that their members have not enjoyed the same degree of benefits that southern consumers have experienced with regards to the joint marketing of integrated telecommunications packaging, including one-stop shopping and customizing of service packages. WCC and YCC pointed out that their members require quick deployment of multiple integrated services and submitted that the necessity for customers to contact multiple service representatives and reproduce information to identify their needs was an unnecessary and costly delay.

34. YG submitted that it has an interest in ensuring the development of telecommunications services and infrastructure for the overall benefit of users throughout Yukon, including both a viable northern-based service provider as well as opportunities for competitive entry, particularly by locally-based service providers. YG argued that there was evidence of both the reality and the opportunity for locally-based competitors to offer integrated service or service packages as alternatives, or value-added services, in competition with Northwestel.

35. YG argued that Northwestel should have a fair opportunity to utilize its competitive capabilities in the northern market and not be disadvantaged by asymmetric rules that allow larger competitors to better position themselves. However, YG expressed its concern that changes in the existing regulatory framework should not have a detrimental effect on the development of smaller, northern-based competitors. In YG's view, increasing Northwestel's flexibility, without establishing a regulatory and pricing framework that permits locally-based service providers the same opportunity to compete, could impair the development of a competitive environment in the north.

36. YG noted that the Commission has recently reviewed the affiliate rule, and established clear guidelines for ILECs in relation to the bundling of tariffed and forborne services within their operating territories in Regulatory safeguards with respect to incumbent affiliates, bundling by Bell Canada and related matters, Telecom Decision CRTC 2002-76, 12 December 2002 (Decision 2002-76). YG noted that Decision 2002-76 did not specifically refer to Northwestel.

37. YG submitted that it would be advisable to consider Northwestel's application in the context of an overall review of the telecommunications regulatory framework in the north.

Northwestel's reply comments

38. Northwestel submitted that the argument made by NNN that the current restrictions on joint marketing should remain since local wireline competition was not yet permitted in the north ignored the fact that, although local wireline competition was not permitted in most independent telephone companies located in the south, the Commission has, however, lifted the joint marketing restrictions in order to better respond to customer needs. In this regard, Northwestel noted the acknowledgment of NNN that customers often prefer the convenience of one-stop shopping for a range of telecommunications services both to aid efficiencies and the timeliness of service.

39. Northwestel argued that the removal of the joint marketing restrictions would not impede the continued development of competition in the north but rather, as the Commission has concluded for the rest of Canada, their removal would better respond to customer needs in the north.

Commission analysis and determination

Joint marketing

40. The Commission acknowledges Northwestel's submission that a number of significant changes have taken place since Northwestel's previous application to remove the joint marketing restrictions was denied in Order 2000-396. These changes include the establishment of a framework for long distance competition with the issuance of Decision 2000-746.

41. The Commission is of the view that long distance competition in Northwestel's territory is continuing to evolve and has made progress since the issuance of Order 2000-396. The Commission is also of the view that as competition is growing, so too is consumer awareness as to the availability of competitive services. The Commission further recognizes consumers' demands for the convenience of one-stop shopping and integrated services. In light of the above, the Commission is of the view that the lifting of the joint marketing restrictions would not be a deterrent to the development of competitive markets but would contribute to meeting consumer expectations and also lead to increased consumer convenience and choice.

42. The Commission acknowledges the position taken by Northwestel that there has been a rapid growth in wireless competition since the issuance of Order 2000-396, particularly in its affiliate's most profitable areas, with competitors offering comprehensive packages that compete as substitutes to local and long distance wireline services which are advertised extensively. The Commission further notes that competitive wireless services are marketed by a number of competitors at various retail outlets in a number of communities in Northwestel's territory. Since Order 2000-396 was issued, there has been growth in wireless competitive services, the marketing of which contributes to competitive choice and consumer awareness of availability of competitive services. In light of the above, the Commission is of the view that if the joint marketing restrictions were lifted for Northwestel, wireless competition would not be discouraged.

43. In addition, the Commission is of the view that while local wireline service may not be open to competition in the foreseeable future, this should not in itself pose an impediment to the lifting of the joint marketing restrictions.

44. With respect to the safeguards related to the requirement for neutral customer referrals, the Commission is of the view that in light of the consumer awareness of the availability of competition as noted above, they are no longer necessary. In addition, with regard to the exchange of confidential customer information, the Commission considers that safeguards such as the Northwestel Terms of Service and the conditions with respect to confidential customer information imposed on wireless carriers, including NMI, as a condition of forbearance, would serve to protect the privacy of the consumer.

45. With respect to cross-subsidization of wireless by wireline services, the Commission notes that this would be identified as a result of the accounting separation between the separate entities of Northwestel and NMI and the associated intercorporate transactions which would continue to apply. The Commission further notes that there are also the additional safeguards of regulatory proceedings and annual Phase III reporting, as Northwestel is still subject to the rate base/rate of return form of regulation with annual supplemental funding reviews.

46. With respect to the request that this application should be considered in the context of an overall review of the telecommunications regulatory framework in the north, the Commission notes that in paragraph 126 of Northwestel Inc. - Initial annual review of supplemental funding, Telecom Decision CRTC 2003-39, 20 June 2003, it concluded that any consideration of a change in Northwestel's regulatory framework should be examined as part of Northwestel's 2004 supplemental funding review. In that decision, the Commission indicated that at the time of this review, it will determine whether the current form of regulation continues to be appropriate or needs to be replaced by either a transitional regime or a direct move to price regulation.

47. The Commission, however, considers that this application should be dealt with at this time, as in light of the above, the Commission is of the view that the joint marketing restrictions applicable to Northwestel are no longer required. Further, the Commission is of the view that Northwestel should be treated more like its ILEC counterparts in the rest of Canada and no longer be the sole incumbent still subject to the joint marketing restrictions. Accordingly, the Commission approves Northwestel's application.

48. The Commission further notes, however, that coupled with lifting the joint marketing restrictions and in regard to treating Northwestel more like its ILEC counterparts, it is also of the view that consideration should be given to the Commission's recent determinations with respect to the rules on the bundling of services, the related modifications to the affiliate rule and the associated regulations of Canadian carriers under common control with an ILEC. These matters are addressed below.


49. The Commission notes that it established bundling rules and the imputation test in Decision 94-19 for the bundling of monopoly services with competitive service elements and for the bundling of customer-specific arrangements (CSAs), for the major ILECs, including Northwestel. Subsequent to Decision 94-19, the bundling rules were modified further in a number of decisions/orders for the major ILECs, excluding Northwestel. In Decision 97-8, the Commission expanded the scope of Decision 94-19 to permit the bundling of local services with forborne services. In Decision 98-4, the bundling rules were also extended to the bundling of tariffed services with services of an affiliated or non-affiliated company and/or non-telecommunications services offered in-house by the major incumbent telephone companies.

50. Further, in Bundling framework developed for customer-specific arrangements, Order CRTC 2000-425, 19 May 2000, the Commission established the rules for CSAs that bundle tariffed telecommunications services with non-tariffed and/or non-telecommunications services and created criteria for bundling tariffed and forborne services consistent with the competitive marketplace.

51. The Commission is of the preliminary view that, coupled with the lifting of the joint marketing restrictions and in line with treating Northwestel more like its counterparts in the rest of Canada, Northwestel should also comply with all the Commission's bundling rules to protect against anti-competitive behaviour and ensure there is a clear distinction between the bundling of services and the joint marketing of services. The Commission directs Northwestel to show cause, within 21 days of the date of this decision, as to why these rules should not be implemented.

Affiliate rule

52. In Decision 2002-76, the Commission made modifications in regard to the affiliate rule. The modifications included a change to the definition of "affiliate" along with changes to the conditions under which an ILEC may provide tariffed services to an affiliate. More specifically, the Commission changed the definition of "affiliate" to include only those persons that are not Canadian carriers and that controls or are controlled by the ILEC or that are controlled by a person that also controls the ILEC. In all cases, control means direct or indirect control in fact.

53. The Commission also changed the conditions under which an ILEC may provide tariffed services to an affiliate in that an ILEC may not provide an affiliate with non-forborne services which the affiliate uses to provide telecommunications services to the public, except pursuant to an approved tariff which identifies the rates, terms and conditions under which the relevant telecommunications services are provided by the affiliate to the public. Those rates, terms and conditions must be identical to the rates, terms and conditions which would apply if the telecommunications services in question were provided to the public by the ILEC, instead of by the affiliate.

54. The Commission is of the preliminary view that along with the lifting of the joint marketing restrictions it would also be appropriate to have Northwestel comply with the modifications to the affiliate rule. This would bring the company more closely in line with the major ILECs and ensure, as the Commission pointed out in paragraph 159 of Decision 2002-76 with respect to the modifications to the affiliate rule, that ILEC tariffed services are provided to the public in a manner that is in full compliance with the Commission's regulatory rules, including with respect to bundling and the application of imputation tests. The Commission directs Northwestel to show cause, within 21 days of the date of this decision, as to why these modifications should not be implemented.

Common control

55. The Commission further notes that in Decision 2002-76, coupled with the modifications to the affiliate rule, it also found it necessary to review the regulation of Canadian carriers under common control with an ILEC (common control, as set out in paragraph 74 c) of Decision 2002-76).

56. In that decision, the Commission expressed the preliminary view that services provided by such a Canadian carrier should be entitled to forbearance if and only if the same services would be entitled to forbearance if they were provided by the ILEC. The Commission also expressed the preliminary view that any non-forborne telecommunications services provided by such a Canadian carrier should be subject to the same rules and requirements as would apply if the services were provided by the ILEC. The Commission invited the large ILECs to show cause why the Commission should not implement its preliminary view with respect to the regulation of Canadian carriers under common control with an ILEC.

57. The Commission also indicated in that decision that, as an interim measure while the Commission considered the regulation of Canadian carriers under common control with an ILEC, such Canadian carriers could not resell any tariffed service of an affiliate ILEC, except pursuant to a tariff filed by the Canadian carrier and approved by the Commission. This prohibition did not apply to the resale of tariffed asymmetric digital subscriber line access service to Internet service providers.

58. The Commission is of the preliminary view that along with the lifting of the joint marketing restrictions, the Commission's views with respect to the regulation of Canadian carriers under common control with an ILEC, along with the interim measure noted above, should also apply to Northwestel, to again bring the company more in line with its major ILEC counterparts. The Commission directs Northwestel to show cause, within 21 days of the date of this decision, as to why this should not be implemented.

Show cause process

59. Northwestel's show cause submissions should be filed with the Commission and copies served on interested parties to this proceeding by 20 October 2003. Interested parties may file comments on these submissions by 27 October 2003, serving copies on Northwestel and all other interested parties. Northwestel may file reply comments by 3 November 2003, serving copies on all interested parties who filed comments. Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent by that date.

Secretary General

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