ARCHIVED - Telecom Procedural Letter Addressed to Distribution List

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Ottawa, 19 January 2016

Our reference: 8663-B2-201514050


Distribution List (See Attachment)

RE: Bell Canada - Application requesting that the Commission replace Carrier obligations to impose certain conditions of service on Non-Carriers with direct regulatory requirements applicable to Non-Carriers

In an application dated 21 December 2015, Bell Canada requested that the Commission remove the current obligations imposed on Canadian carriers to impose certain conditions of service on non-carriers (underlying carrier obligations) and, instead, impose these requirements directly on non-carriers using its jurisdiction under section 24.1 of the Telecommunications Act. In an attachment to its application, Bell Canada listed some of the obligations that Canadian carriers are obligated to impose on non-carriers (also known as resellers). These underlying carrier obligations include matters related to 9-1-1 service and to matters associated with the Commissioner for Complaints for Telecommunications Services Inc. (CCTS) which are the subject of separate proceedings.

Because the above noted issues are the subject of separate proceedings, this letter is to advise interested persons that the issues considered in the following two proceedings are not within the scope of the proceeding initiated by the Bell Canada application referenced above. To the extent that interveners file comments on these issues, they will not be considered:

Interveners are also to prioritize the underlying carrier obligations, both those identified by Bell Canada as part of its application and any other underlying carrier obligations interveners may identify, to assist the Commission to determine, if necessary, the order in which the obligations should be addressed.

In view of the foregoing, the process for responding to the Bell Canada application is hereby extended. Any interested person may file an intervention by 22 February 2016. Bell Canada may file a reply to any intervention by 3 March 2016, serving a copy on all interveners.

Relevant background information can be found in the Appendix to this letter.


Original signed by Suneil Kanjeekal for

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c: Jesslyn Mullaney, CRTC, 819-953-5255,
Philippe Gauvin, Bell Canada,

Attach. (2)


Distribution List



As part of Economic Action Plan 2014 Act, No. 2Footnote 2, Parliament amended the Telecommunications Act to expand the scope of the Commission's jurisdiction through the introduction of section 24.1. Under this new section, the Commission now has the power to impose directly on non-carriers conditions related to the offering and provision of telecommunications services.

Prior to this amendment, to apply regulatory obligations on non-carriers, the Commission required, through a section 24 condition, the underlying carriers to include certain obligations on non-carriers through the carriers’ contractual arrangements with the non-carriers (underlying carrier requirement).

In Broadcasting and Telecom Notice of Consultation 2015-239, the Commission initiated a public proceeding under both the Broadcasting Act and the Telecommunications Act to review matters associated with the CCTS. Amongst other things, parties were asked to respond to the following question:

With the recent amendments to the Telecommunications Act that allow the Commission to directly impose conditions of service on resellers, should the requirement that TSPsFootnote 3 participate in the CCTS be imposed directly on resellers on a going-forward basis?

Final submissions were filed on 20 November 2015 and a decision is expected within four months of the close of record.

In Telecom Regulatory Policy 2016-12, the Commission issued its decision on the proceeding initiated by Application of the 9-1-1 regulatory obligations directly to non-carriers, Telecom Notice of Consultation CRTC 2015-369, 12 August 2015, in which parties were to show cause why the existing 9-1-1 obligations should not directly apply to non-carriers that provide local exchange, wireless voice, local voice over Internet Protocol, or payphone services. The Commission also invited comments on whether the underlying carriers should continue to be subject to the Commission’s requirement that they apply the 9-1-1 obligations to non-carriers through their contractual arrangements with the non-carriers.


Footnote 1

Final submissions were filed on 20 November 2015.

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Footnote 2

S.C. 2014, c.39

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Footnote 3

Telecommunications service providers

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