ARCHIVED - Telecom Procedural Letter Addressed to Kenneth G. Engelhart (Rogers Communications Partnership)

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Ottawa, 27 February 2015

File number: 8633-R28-201501586

Mr. Kenneth G. Engelhart
Senior Vice President – Regulatory
Rogers Communications Partnership


Re: Rogers’s Part 1 Application for Clarification Under Telecom Regulatory Policy CRTC 2013-271 – The Wireless Code – Request to disclose information claimed as confidential

Dear Mr. Engelhart:

With this letter, Commission staff is requesting disclosure of the following documents submitted in confidence by Rogers Communications Partnership (Rogers) in this Part 1 Application:

A. Rogers’ Part 1 application:   Partie 1 _ Part 1 Rogers Communications – Disconnections Part 1 Jan 15

At the time that Rogers filed this application, it designated part of the above information as ‘confidential’ pursuant to section 39 of the Telecommunications Act (the Act) and the Appendix to Telecom Information Bulletin CRTC 2010-961. Rogers provided the following reason for its designation of confidentiality for this information: 

“The release of this information would provide Rogers’ existing and potential competitors with strategic information with regard to Rogers’ collection strategy not otherwise available to them, from which they could develop more effective business strategies. The release of this information can reasonably be expected to prejudice Rogers’ competitive position thereby causing the company direct and specific harm.”

We note that the Commission stated in Bulletin 2010-961 that:

“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.”

Commission staff considers that the release of the information identified above would be in the public interest as it would facilitate meaningful comment by interested parties on the clarification of the Wireless Code sought by Rogers and would promote the creation of a fuller record for this proceeding. In the view of Commission staff, Rogers has not provided sufficiently specific rationale to justify why disclosure of this information is not in the public interest, nor did it explain how the information at issue is of a type listed in the Appendix to Bulletin 2010-961.

To more efficiently focus Rogers’ reply on the information staff considers should be on the public record of this proceeding, staff is enclosing as Attachment A a copy of the information deemed confidential in Rogers’ Part 1.

Rogers may file a reply to this request no later than 9 March 2015.



Nanao Kachi
Director, Social and Consumer Policy, CRTC


Enclosed: Attachment A: Clarifications on information marked as CONFIDENTIAL in Rogers’ Part 1 Application (NOT WEB)

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