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Ottawa, 30 August 2013

Our Reference: 8633-R28-201310820, 8633-T66-201310812 and 8622-Q15-201310508


Mr. Tamir Israel
Staff Lawyer
Samuelson-Glushko Canadian Internet Policy
& Public Interest Clinic
University of Ottawa
Faculty of Law - Common Law Section
57 Louis Pasteur Street
Ottawa, Ontario K1N 6N5

Re: Procedural Request – Part 1 Applications relating to Telecom Regulatory Policy CRTC 2013-271

Dear Mr. Israel:

The Commission is in receipt of a request, dated 26 August 2013, from the Samuelson-Glushko Canadian Internet Policy & Public Interest Clinic and Open Media Engagement Network (collectively, CIPPIC/Open Media) to provide interveners with an opportunity to file reply comments on certain applications [1] related to the Wireless Code. [2]

The applications, filed by Rogers Communications Partnership (Rogers), TELUS Communications Company and Quebecor Media Inc. (Quebecor), relate to the implementation and interpretation of the Wireless Code, which will take effect on 2 December 2013. The applications were submitted between 16 and 22 July 2013. Interested persons were provided until 26 August 2013, to comment. Under the current schedule, only the applicants may submit reply comments, which are to be filed no later than 3 September 2013.

CIPPIC/Open Media argued that, due to the interrelated nature of the applications and the public interest issues, all parties should have an additional opportunity to comment. They requested that the Commission provide all parties until 10 September 2013, to submit reply comments. Quebecor and Rogers opposed this request. [3] They expressed concern about the time that has elapsed since they filed their applications in light of the implementation date for the Wireless Code.

Commission staff notes that interested persons were provided over 30 days to comment on the applications. Commission staff also notes that CIPPIC/Open Media submitted comments on 26 August 2013. Commission staff considers that if it were to provide all parties with an additional comment period, it would usually also have to provide the applicants with an additional reply period.

Commission staff further notes that the Commission’s determinations in these applications could have significant impact on wireless service providers and Canadian consumers of wireless services. Commission staff considers that these applications
must be concluded in advance of the implementation of the Wireless Code on
2 December 2013 and should be addressed as expeditiously as possible.

In light of these constraints, Commission staff does not consider that an additional reply by all parties is in the public interest.


Steven Harroun
Acting Director General, Strategic Policy
Consumer Affairs and Strategic Policy

c.c.: Neil Barratt, CRTC
Kenneth G. Engelhart, Rogers
Dennis Béland, Quebecor

Distribution List;;;;;;;;;;;;;

[1] File numbers: 8633-R28-201310820, 8633-T66-201310812 and 8622-Q15-201310508
[2] The Wireless Code is set out in Telecom Regulatory Policy CRTC 2013-271.
[3] In letters dated 27 and 28 August 2013, respectively

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