ARCHIVED - Letter addressed to Mr. Jonathan Holmes (Independent Telecommunications Providers Association)

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Ottawa, 2 July 2015

Our reference: 8661-C136-201506049


Mr. Jonathan Holmes
Executive Director
Independent Telecommunications Providers Association

RE: Part 1 Application Requesting Expedited Process - SILEC DC Rate - Proxy Application

Dear Mr. Holmes:

The Commission is in receipt of a Part 1 application dated 15 June 2015, in which the Canadian Independent Telephone Company, Joint Task Force (JTF), which includes members of both l’Association des compagnies de téléphone du Québec and the Independent Telecommunications Providers Association, requested that the Commission:

  1. Permit small Incumbent Local Exchange Carriers (SILECs) to adopt Execulink Telecom Inc.’s (Execulink) Direct Connect (DC) service rate as a proxy for their own DC rate.
  2. Dispense with the standard Part 1 intervention and reply deadlines and set shorter deadlines such that interventions must be filed within 15 days and reply within a further 5 days, with a Commission decision to be issued within 60 days of the close of record.

On 19 June 2015, TELUS Communications Company (TELUS) objected to the JTF’s request to set shorter intervention and reply deadlines. Specifically, TELUS submitted  that there is no financial risk given that the current DC rate for each of the companies in question is higher than the DC rate recently finalized for Execulink. TELUS also considers that the issue cannot be considered so urgent that the normal application process be shortened given that the JTF did not have to wait until Execulink’s rate was finalized to file its application. Finally, TELUS submitted that its current regulatory workload would not allow TELUS to respond before July 8.
The Commission agrees with TELUS that because the current interim DC rates are higher than the rate approved for Execulink, the interim regime does not result in a significant negative financial impact on the parties represented by the JTF.  Further, it is important that parties be given adequate time to develop a proper and fulsome record to assist the Commission in making its decision on the JTF’s proposal. Therefore, the Commission is not persuaded that the standard intervention and reply deadlines for this application should be abridged.

Accordingly, JTF’s request is denied. The procedural timelines remain as set out in the Canadian Radio-television and Telecommunications Rules of Practice and Procedure governing Part 1 applications.


Original signed by

John Traversy
Secretary General

c.c. Serge Désy, ACTQ,
Stephen Schmidt, Telus, Regulatory.Affairs@TELUS.COM
Bart Cameron, Bruce Telecom,
Don Holkestad, CityWest Telephone,
Michel Laurent, CoopTel,
Guy Cordeau, Groupe Maskatel,
Kolos Gugan, Wightman Telecom,
Dennis Beland, Videotron,
David Watt, Rogers,
Stella Wallace-Chagnon, Bell Aliant,
Philippe Gauvin, Bell Canada,
Stacy Langley, Bragg/Eastlink,
Paul Cowling, Shaw Telecom,
Russ Friesen, MTS Allstream,
Robert Hersche, SaskTel,
Michel Messier, Cogeco,
Rob Olenick, TBayTel,
Jean-Francois Leger, PIAC,

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