ARCHIVED - Telecom Procedural Letter Addressed to Distribution List

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Ottawa, 18 March 2016

Our references: 8740-T66-201513028, 8740-R28-201513010, 8740-B38-201507849, 8740-B38-201600023


Distribution list

RE: Telecom Regulatory Policy CRTC 2015-177 – Regulatory framework for wholesale mobile wireless services – Follow-up process to finalize GSM-based wholesale roaming services proposed tariffs for the National Wireless Carriers –Disclosure of confidential information

This letter addresses requests for disclosure of information designated as confidential in the proposed tariff filings dated 23 November 2015 of TELUS Communications Company (TCC), Rogers Communications Partnership (Rogers) and Bell Mobility (collectively the national wireless carriers), following determinations in Telecom Regulatory Policy 2015-177 (TRP 2015-177).

In TRP 2015-177, the Commission directed the national wireless carriers to submit their respective proposed cost-based tariffs for domestic Global System for Mobile communications (GSM)-based wholesale roaming services for voice, text message and data, supported by regulatory economic studies consistent with the Commission’s Phase II costing approachFootnote 1 .

On 15 January 2016, WIND Mobile Corp. (WIND), Bragg Communications Inc., carrying on business as Eastlink (Eastlink), Quebecor Media Inc., on behalf of Videotron s.e.n.c. (Videotron) and Corridor Communications Inc. (CCI) filed submissions requesting disclosure of certain information for which confidentiality had been claimed by the national wireless carriers in connection with their filings dated 23 November 2015. On 29 January 2016, the national wireless carriers replied to these requests.

Commission staff notes that requests for disclosure of information designated as confidential are addressed in light of sections 38 and 39 of the Telecommunications Act (the Act) and sections 30 and following of the CRTC Rules of Practice and Procedure (the Rules of Procedure). In evaluating a request, an assessment is made as to whether the information falls into a category of information that can be designated as confidential pursuant to section 39 of the Act. An assessment is then made as to whether there is any specific direct harm likely to result from the disclosure of the information in question and whether any such harm outweighs the public interest in disclosure. In making this evaluation, a number of factors are taken into consideration, including the degree of competition and the importance of disclosure of the information for the purpose of obtaining a fuller record. The factors considered are discussed in more detail in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, as amended by Broadcasting and Telecom Information Bulletin CRTC 2010-961-1, 26 October 2012.

Commission staff also notes that this analysis applies only to requests for disclosure of information already filed on the record. Requests for new or additional information are more appropriately dealt with as interrogatories.

Commission staff has reviewed the requests filed by WIND, Eastlink, Videotron and CCI, as well as reply comments from the national wireless carriers and considers that additional disclosure is necessary at this stage of the proceeding for parties to be able to intervene meaningfully.

In light of the above, Commission staff considers that the national wireless carriers are to disclose on the public record all information set out in Attachment 1 by 24 March 2016.

In addition, Commission staff advises all parties that the next steps of the ongoing proceeding to review and finalize the proposed tariff pages for wholesale wireless roaming services are as follows:

  1. All interested persons may file interventions in relation to the national wireless carriers’ economic studies in support of the proposed cost-based rates and the terms and conditions included in the proposed tariff pages by 8 April 2016. Commission staff advises that only interested persons who participate at this stage may submit requests for information or participate in future rounds of this proceeding.

  2. The national wireless carriers may file their reply comments to the interventions from parties by 18 April 2016.

  3. Parties and Commission staff may submit requests for information by 9 May 2016.

  4. The national wireless carriers are to file responses to requests for information from parties and Commission staff by 30 May 2016.

  5. Any request for further information or public disclosure of information designated confidential by the national wireless carriers must be made 6 June 2016.

  6. The national wireless carriers are to file their response to requests for further information and public disclosure by 13 June 2016.

Commission staff expects that after the request for further information and public disclosure are completed, further process will be set out to allow parties an opportunity for further comment and reply.

Parties are asked to serve all other parties with any documents filed in this proceeding, and to send an electronic copy directly to the following Commission staff:


Original signed by Tom Vilmansen for

Lyne Renaud
Director, Competitor Services and Costing Implementation
Telecommunication Sector

c.c.: Abderrahman El Fatihi, CRTC, (819) 953-3662,
William Lloyd, CRTC, (819) 997-4654,

Attach (1)

Distribution list:


Bell Mobility

  1. The capacity in Megabytes associated with wireless radio spectrum (Attachment 1 – Appendices 6, 7, 8 - Table 6b- Capital, Section A.1, Capacity in Megabytes of Radio Spectrum, Major Capital Items, cell M19).

  2. The statement on the forecast of new entrants demand in Attachment 1 – Bell Mobility Report on the Economic Evaluation for the Tariff Revisions of National Wireless Roaming Service, Page 8 of 15, paragraph 19.


  1. The conversion factors, separately for each technology, used to translate voice and text message (or SMS) demand into equivalent Megabytes (from worksheet “PV Demand” in Rogers’ Wireless Phase II Costing Model).

  2. Column E of Table 6.b. Spectrum, Capital Causal to Service – Other, in Rogers’ Wireless Phase II Costing Model, which provides details used to determine the fair market valuation of each band of its radio spectrum portfolio.

  3. The start study and annual wholesale demand forecasts for voice in minute, SMS in messages and data in MB (from worksheet “Model” in Rogers’ Wireless Phase II Costing Model).

  4. The useful life of capital items included in the cost study (from worksheet “Capital Item Summary” in Rogers` Wireless Phase II Costing).


  1. The start study wholesale demand by service in minutes, messages and MB (from worksheet “Services Demand” in TELUS’ NERA Mobile Model).

  2. All financial parameters and tax rates used in the economic study (Table 4 – Financial Parameters and Tax Rates, TELUS Communications Report on the Economic Evaluation for Wholesale Mobile Wireless Services for GSM-based domestic Wholesale Roaming: Data, Voice and SMS).


Footnote 1

Paragraph 141, TRP 2015-177

Return to footnote 1

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