ARCHIVED - Telecom Commission Letter addressed to Suzanne Morin (Bell Aliant Regional Communications, L.P.), Philippe Gauvin (Bell Canada)

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Ottawa, 8 October 2014

File No.: 8650-C12-201310060


Ms. Suzanne Morin
General Counsel – Regulatory and Privacy Chief
Bell Aliant Regional Communications, L.P.
160 Elgin Street, Floor 19
Ottawa, Ontario  K2P 2C4

Mr. Philippe Gauvin
Senior Counsel – Regulatory Law & Policy
Bell Canada
Floor 19
160 Elgin Street, Floor 19
Ottawa, Ontario  K2P 2C4

Re:  Request to Bell Aliant and Bell Canada to disclose certain information designated as confidential in its intervention to Notice of Consultation 2013-337, Fact-finding on the role of payphones in the Canadian communications system.

Dear Ms. Morin and Mr. Gauvin:

This is with reference to the request for confidential treatment of information made by Bell Aliant and Bell Canada (the Companies) contained in paragraph 19 of the Companies’ 15 November 2013, intervention filed on the record of the above-named proceeding, and in paragraph 17 of its revised intervention filed on 14 February 2014, set out below:  

The impact of removals is minimized by only targeting payphones that are receiving the lowest levels of usage amongst the Companies' payphone base.  For example, in Ontario and Québec, the Companies are currently maintaining    #    payphones that have generated no revenue over the last 13 months. The Companies maintain a further # payphones that have generated, on average, less than $0.50 per day over that same period, for a total of  # particularly low-usage payphones, which represents      # of the Companies' in service payphone base.  As noted in The Companies(CRTC)16Jul13-101 TNC 2013-337, the Companies intend to remove 8,374 low-usage payphones in 2014.

In support of their request for confidentiality, the Companies provided the following rationale, which applied generally to all the information filed in the intervention in respect of which confidentiality was sought:

Release of this information would provide potential competitors with invaluable competitively-sensitive information that would not otherwise be available to them, and which would enable them to develop more effective business strategies.  Release of such information could prejudice the Companies' competitive position resulting in material financial loss and cause specific direct harm to the Companies. 

The Companies are requested to explain why the information submitted in confidence in the paragraph set out above should not be disclosed on the public record.  In particular the Companies should explain how this information is of a type listed in the appendix to Bulletin 2010-961 and provide a detailed rationale to explain why disclosure of this information is not in the public interest. Commission staff notes that at paragraph 6 of Bulletin 2010-961, the Commission states:

Generic statements such as “the release of this information to competitors would result in specific, direct harm to the company” are not sufficient.  Parties must provide sufficient reasons to allow meaningful analysis by the Commission or another party who may wish to request disclosure of the information.

Bell Aliant and Bell Canada are to file its response no later than five days after receipt of this letter.

Should you have questions concerning any of the above, please contact Soniya Mukhedkar by telephone at 819-997-4754 or by email at


[Original signed]

Nanao Kachi
Director, Social and Consumer Policy


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