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Ottawa, 8 August 2013

Reference no.: 8620-R28-201308750

BY E-MAIL

Faye Hughes
Regulatory Analyst
Bruce Telecom
3145 Highway 21 North
Tiverton, ON N0G 2T0
regulatory@brucetelecom.com

Simon-Pierre Olivier
Director, Regulatory Affairs
Rogers Communications Partnership
rci.regulatory@rci.rogers.com

RE: Request to implement Wireless Number Portability in the exchanges of Tiverton, Kincardine and Paisley (Ontario)

Dear Sir/Madam,

On 24 April 2013 Rogers Communications Partnership (RCP) provided to Bruce Telecom a formal expression of interest to open the exchanges of Tiverton, Kincardine and Paisley (Ontario) for Wireless Number Portability (WNP). Pursuant to Telecom Decision 2008-122, Regulatory framework for the implementation of wireless number portability within the serving territories of the small incumbent local exchange carriers (Telecom Decision 2008-122), Bruce Telecom was to have filed an implementation plan within 30 days of the request.

In a letter dated 17 May 2013, Bruce Telecom requested an extension of 90 days, citing on-going delays experienced in implementing WNP in the exchange of Port Elgin. RCP opposed Bruce Telecom’s request for an extension, indicating that Bruce Telecom was responsible for the majority of the delays. Commission staff granted Bruce Telecom an extension of 45 days and indicated that the implementation plans were to have been filed no later than 8 July 2013.

Citing resource constraints and the need to first complete WNP testing in Port Elgin, Bruce Telecom has subsequently requested an extension to allow the filing of its WNP implementation plan within 21 days of WNP being implemented in the Port Elgin exchange.

Commission staff recognizes that Bruce Telecom has limited staff resources; however, Commission staff considers that Bruce Telecom has been given sufficient time to prepare its WNP implementation plan. Staff further notes that wireless consumers in the Tiverton, Kincardine and Paisley exchanges cannot benefit from WNP until Bruce Telecom moves the process along by filing its implementation plans in accordance with the Commission’s explicit directives in Telecom Decision 2008-122. Further, staff considers that the filing of WNP implementation plans for Tiverton, Kincardine and Paisley is not dependent on full implementation of WNP in Port Elgin. Staff notes that the implementation plan can be modified at a later date if the testing process for Port Elgin reveals new issues or information.

As a result, Commission staff considers that an additional extension for the filing of the WNP implementation plan would not be appropriate and Bruce Telecom is to file its WNP implementation plan no later than 21 August 2013.

Yours sincerely,

Original signed by:

Mario Bertrand
Director, Dispute Resolution

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