ARCHIVED - Telecom Commission Letter Addressed to Philippe Gauvin (Bell Canada)

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Ottawa, 20 February 2017

Our reference: 1011-NOC2016-0293


Philippe Gauvin
Senior Legal Counsel
Bell Mobility
Floor 19, 160 Elgin Street
Ottawa, ON  K2P 2C4

Re: Wireless Code Review – Bell Mobility Procedural Request

Dear Sir:

Bell Mobility appeared at the public hearing component of the Wireless Code Review proceeding on 7 February 2017.Footnote 1 During that appearance, Bell Mobility undertook to file responses to a number of questions from Commissioners and Commission legal counsel by no later than 16 February 2017. These undertakings included the questions set out in CRTC Exhibit 1, which was tabled on 6 February 2017.

On 16 February 2017, Bell Mobility filed a procedural request to extend the deadline to respond to eleven of these questions until 20 March 2017.  Bell Mobility argued that the magnitude of the changes that would be required to its systems and processes prevented it from providing responses to questions concerning the cost of implementation of various proposed changes to the Wireless Code.

In reply to Bell Mobility’s procedural request, Rogers Communications (Rogers) and TELUS Communications Company (TCC) filed letters dated 16 February 2017, submitting that they would be prejudiced by filing their own responses to these questions before the Commission disposed of the procedural request.

No other wireless service provider (WSP) that appeared at the public hearing failed to file responses to their own undertakings.Footnote 2

Bell Mobility’s request would significantly alter the timelines associated with this proceeding and would inevitably delay the Commission’s deliberations of the issues raised and ultimate determinations in these matters. In the circumstances, it is not clear that such a delay would be appropriate. Further, Bell Mobility has made assertions regarding its ability to comply with the pre-established deadline, but has provided minimal explanation or support for these assertions, and the Commission notes that no other WSP has made similar arguments regarding the ability to provide similar information by the pre-established deadline. Finally, the Commission expects that parties who agree to specific timelines make the necessary inquiries to determine their ability to comply with these timelines as early as possible.

Accordingly, the Commission denies Bell Mobility’s procedural request. Bell Mobility, Rogers and TCC are to file responses to all questions they undertook to answer during the public hearing by no later than 22 February 2017, using the best available information. All other parties that filed responses to undertakings may update any information in their responses by this same date, should they so choose.

The deadline for final replies shall remain 27 February 2017, as set out in Telecom Notice of Consultation CRTC 2016-293-5.

Yours Sincerely,

Danielle May-Cuconato
Secretary General


Distribution List:

Wireless Service Providers

Bell Mobility (

Bragg Communications Inc, dba "Eastlink" (

Quebecor Media Inc., on behalf of its subsidiary Videotron G.P. (

Rogers Communications Canada Inc. (

Saskatchewan Telecommunications (SaskTel) (

SSi Micro Ltd. (

TELUS Communications Company (

WIND Mobile Corp. (

Consumer Groups

The Coalition, composed of the Consumers’ Association of Canada (CAC), Council of Senior Citizens Organizations of British Columbia (COSCO), National Pensioners Federation (NPF) and Public Interest Advocacy Centre (PIAC) (

Comité pour le service cellulaire équitable L'Islet (

Consumers Council of Canada (;

Deaf Wireless Canada Consultative Committee (

Media Access Canada, on behalf of the Access 2020 Coalition of Disabilities Stakeholders (

Union des consommateurs (

Other Parties

Canadian Wireless Telecommunications Association (

Commissioner for Complaints for Telecommunications Services Inc. (

Community Legal Aid (

Dr. Catherine Middleton, Canada Research Chair, Ted Rogers School of Management, Ryerson University and Dr. Tamara Shepherd, Assistant Professor, Department of Communication, Media and Film, University of Calgary (;

Forum for Research and Policy in Communications (

Group of Students from Huntington University at Laurentian University (

Group of researchers composed of Marina Pavlovic, Mary Cavanagh, Sean Grassie and Lora Hamilton (

Ministère de la Culture et des Communications du Québec et l'Office de la protection du consommateur (

Vaxination Informatique (

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