ARCHIVED - Telecom Commission Letter Addressed to the Distribution List

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Ottawa, 23 September 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 – Requests for disclosure of information designated as confidential and for further responses to requests for information with respect to Costing and Rates

Dear Madam, Sir:
This letter addresses requests for disclosure of information designated as confidential and for further responses to interrogatories related to costing with respect to the rates for wholesale roaming services proposed by the National Wireless Carriers.Footnote 1

This letter addresses only requests related to the proposed tariffed rates. Requests for disclosure and further information regarding the terms and conditions for these services were addressed in a letter from Commission staff dated 29 August 2016.

On 12 August 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 Ice Wireless Inc. (Ice Wireless) filed submissions requesting disclosure of certain information for which confidentiality had been claimed and for further responses to interrogatories.

These requests concerned the responses of the National Wireless Carriers related to costing and rates dated 5 August 2016, to requests for information posed to them on 17 June 2016. On 19 August the National Wireless Carriers responded 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.

With respect to request for further responses to interrogatories, the requirements of section 76 of the Rules of Procedures apply. The merits of arguments both for and against the filing of further responses are taken into account, as well as the general principles enunciated by the Commission in past proceedings. The major consideration is the relevance of the information requested to the matter at issue. The availability of the information requested is also a factor, which is balanced against the relevance of the information. If the provision of the information sought would require an effort disproportionate to the probative value of the information itself, further responses will not be required. Another factor considered is the extent to which an interrogatory answer is responsive to the interrogatory as it was originally asked. Generally, parties are not required to provide further responses to requests for further information from a party that did not ask the original interrogatory.

Commission staff has reviewed the requests filed by WIND, Videotron and Ice Wireless, as well as reply comments from the National Wireless Carriers and considers that additional disclosure and further responses are necessary at this stage of the proceeding in order for parties to be able to intervene meaningfully and for the Commission to obtain a complete record.

In light of the above, Commission staff considers that the parties listed in the Attachment are to disclose the specified information on the public record, or file it with the Commission, as the case may be, by 29 September 2016.

Commission staff expects that after the request for further information and public disclosure are completed, further process will be set out to continue reviewing the wholesale wireless roaming tariffs.

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:

Lyne Renaud,
Abderrahman El Fatihi,
Lloyd, William,

Parties are reminded that, if a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Original signed by

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 life estimates in Table 3, Attachment 1, Column “Life estimate”, Bell Mobility(CRTC)17Jun16-4 TN1B-TN 2,
  2. The “Working Fill Factor for RAN”, the “Practical Max Spectral Efficiency with Network Constraints and WFF”, the “Yearly Max Capacity (MB)/Radio”, the “Network Capacity(MB)” and the “Maximum Network Capacity (MB)” (from worksheet RAN Capacity, of Attachment 2 Bell Mobility(CRTC)17Jun16-4 TN1B-TN 2.
  3. The Total equipped capacity “Erlang Capacity” (Cell D16 from worksheet “Core Capacity”, of Attachment 2 Bell Mobility(CRTC)17Jun16-4 TN1B-TN 2
  4. The working fill factor on page 12 of 13 in Bell Mobility(CRTC)17Jun16-4 TN1B-TN 2, dated 8 July 2016.
  5. All Expenses Increase Factors (EIFs), Capital Increase Factors (CIFs) and Productivity Increase Factors (PIFs) used in the cost study submitted in support of the proposed cost-based rates for the wholesale wireless roaming services (Voice, Text and Data)


  1. The “supplier identified maximum capacity” in Table 3 of Attachment 1, Telus(CRTC)17Jun16-4 for all equipment for which the supplier maximum capacity is used (i.e. Switching system software, Switching system capacity upgrade, Signalling transfer point (STPs), SGSN and GGSN).
  2. The average working fill factors, column “AWFF” in Table 3 of Attachment 1, Telus(CRTC)17Jun16-4.
  3. The Compound Annual Growth Rate (CAGR) by equipment type in page 3 of 4, TELUS(CRTC)17Jun16-14.
  4. The productivity improvement factor (PIF) utilized for 4G spectrum (Note 1 of the Table provided in response b), TELUS(CRTC)17Jun16-14, page 4 0f 4).



  1. The results of the test of reasonableness of the NERA model against TCC’ currently deployed network, in confidence with the Commission with an abridged version on the public record.


Footnote 1

The National Wireless Carriers are, collectively, Bell Mobility Inc. (Bell Mobility), Rogers Communications Partnership (Rogers) and TELUS Communications Company (TCC).

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