ARCHIVED - Letter
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Ottawa, 30 April 2009
File No.: 8620-B7-200905599
BY E- MAIL
Mr. Michael J. Andrews
President and CEO
Bruce Telecom
P.O. Box 80
3145 Highway 21 North
Tiverton ON N0G 2T0
regulatory@brucetelecom.com
Dear Mr. Andrews:
RE: Bruce Telecom wireless number portability implementation plan
By letter, dated 13 March 2009, Rogers Wireless Partnership (Rogers) provided to Bruce Telecom, a formal expression of interest for wireless number portability (WNP) in the exchange of Port Elgin, Ontario.
In Regulatory framework for the implementation of wireless number portability within the serving territories of the small incumbent local exchange carriers, Telecom Decision 2008-122, 18 December 2008, the Commission concluded that small incumbent local exchange carriers (SILECs) should file their proposed WNP implementation plans within 30 days of receiving a formal signed expression of interest form a wireless carrier.
By letter, dated 14 April 2009, Bruce Telecom indicated, among other things, that it was presently dealing with a request for local competition and that, as a result of Rogers ' WNP request, the existing interconnection agreement with the interconnecting incumbent local exchange carrier (ILEC) would require modification and must be reopened.
Bruce Telecom noted that it was unfamiliar with the processes for dealing with each of the requests, i.e. local competition and WNP, and that while there were some commonalities, they were separate requests. Bruce Telecom indicated that it was challenged in managing both processes and requested a ninety day extension for the filing of its WNP implementation plan.
By letter, dated 20 April 2009, Rogers submitted that Bruce Telecom's request for an extension should be denied. Among other things, Rogers argued that the requirement for Bruce Telecom to reopen the interconnection agreement did not justify a delay of 90 days and, given the Commission's past proceedings and decisions relating to WNP, Bruce Telecom has had sufficient time to address WNP issues.
In a reply letter, dated 24 April 2009, Bruce Telecom noted that the interconnection agreement was only recently concluded after years of negotiation. Bruce Telecom indicated that the interconnecting ILEC had acknowledged its request to re-open discussions but noted that to date no discussions had taken place. With regard to Rogers ' assertion that Bruce Telecom has had sufficient time to address WNP issues, Bruce Telecom noted that it did not have the resources to pre-develop implementation plans for future possible events.
Bruce Telecom also invited Rogers to contact it to begin dialogue that would facilitate filing of its WNP implementation plan within the extended timeline requested.
Given that Bruce Telecom is in the process of implementing local competition and that it has limited resources, its request for an extension of ninety days from receipt of Rogers WNP request, for the filing of its WNP implementation plan, is acceptable.
Yours sincerely,
Original signed by
Suzanne Bédard
Senior Manager, Tariffs
Telecommunications
cc: Dawn Hunt, Rogers, (416) 935-7211, rwi_gr@rci.rogers.com
Laurence Amar, Rogers , (416) 473-2394, laurenceamar@rci.rogers.com
Joseph Cabrera, CRTC (819) 934-6352, joseph.cabrera@crtc.gc.ca
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