ARCHIVED - Telecom Procedural Letter addressed to Distribution list

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Ottawa, 4 November 2015

Our reference: 8638-C12-201505661

BY EMAIL

Distribution list

RE: Follow-up to Telecom Regulatory Policy CRTC 2015-177, Regulatory framework for wholesale mobile wireless services (TRP 2015-177) – Request for Extension

Dear Madams/Sirs:

The Commission is in receipt of a letter dated 30 October 2015, submitted by Bell Canada (Bell), requesting an extension to 27 November 2015 for filing of the Bell Mobility proposed rates, terms and conditions for its national wireless roaming service and the supporting cost studies as required by the Commission in Telecom Regulatory Policy CRTC 2015-177 entitled Regulatory framework for wholesale mobile wireless services (TRP 2015-177).

Bell submitted that this is the first time that it has been asked to complete a cost study of this complexity with respect to wireless services, which has required the definition and collection of new inputs. They also submitted that, as the current rates are interim, no party is unduly harmed by the delay.

In letters dated 30 October 2015, Rogers Communications Partnership (RCP) and TELUS Communications Company (TCC) supported Bell’s request and also requested a similar extension for their filing deadlines.

In a letter dated 2 November 2015, Bragg Communications Inc. (Eastlink) objected to the granting of an extension for Bell, RCP and TCC (collectively the national wireless carriers). Eastlink argued that six months was sufficient time for the national wireless carriers to complete their costs studies, as they are large service providers with considerable experience in developing cost studies. Eastlink also argued that, given the Commission’s findings that the national wireless carriers have market power, any delay in implementing cost-based rates will affect the ability of new entrants to expand their wireless network and therefore competition.

The Commission acknowledges the complexity of the work faced by the national wireless carriers. It was for this very reason that the national wireless carriers were given a full six months to prepare and file the proposed tariffs and associated cost studies. The national wireless carriers are sophisticated participants, with considerable experience in preparing regulatory filings.

In light of the above, the Commission is surprised and concerned that the national wireless carriers have indicated that they are effectively not in a position to comply with the regulatory deadline of 4 November 2015 imposed in TRP CRTC 2015-177. This situation is exacerbated by the fact that Bell chose to wait until less than a week before the deadline in question to file its request for an extension.

The filing of proposed rates, terms and conditions, supported by cost studies is an essential step to address the market power exercised by the national wireless carriers. By seeking an extension, the national wireless carriers are effectively delaying the process by which cost-based rates, terms and conditions can be examined and ultimately ruled upon. This is a matter of serious concern to the Commission.

At the same time, the Commission appreciates that the tariff filing process will likely proceed more efficiently if the regulatory filings of the national wireless carriers are complete and are supported by robust evidence.

Given this, the Commission grants an extension on an exceptional basis until 9 a.m. (Ottawa time) 23 November 2015 for the regulatory filings in question. The Commission expects that the quality of the regulatory filings, including the associated cost studies will reflect the additional time provided.

Sincerely,

Original signed by Luc begin for
John Traversy
Secretary General

Attach. Distribution list

Distribution list:
Bell Mobility Inc., bell.regulatory@bell.ca
Rogers Communications Partnership, rwi_gr@rci.rogers.com
TELUS Communications Company, regulatory.affairs@telus.com
Videotron G.P., regaffairs@quebecor.com
Bragg Communications Incorporated (Eastlink), regulatory.matters@corp.eastlink.ca
Globalive Wireless Management Corp. (WIND), lisajackson@globalive.com
TBayTel, rob.olenick@tbaytel.com
MTS Inc., iworkstation@mtsallstream.com
Saskatchewan Telecommunications, document.control@sasktel.com
Ice Wireless Inc., regulatory@icewireless.ca
Canadian Network Operators Consortium Inc. regulatory@cnoc.ca
lawford@piac.ca
Benjamin Klass, benjiklass@hotmail.com
Vaxination Informatique, jfmezei@vaxination.ca

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