ARCHIVED - Telecom Commission Letter Addressed to the Distribution List

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Ottawa, 31 May 2017

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 additional information with respect to second round of requests for information associated with costing and rates

Dear Madam, Sir:

This letter addresses requests for disclosure of information designated as confidential and for further responses to interrogatories, dated 4 April 2017, related to the setting of rates for wholesale roaming services proposed by the National Wireless Carriers.Footnote1

On 18 April 2017, Freedom Mobile Inc. (Freedom Mobile), 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, dated 4 April 2017, of the National Wireless Carriers to interrogatories posed to them on 20 December 2016.

On 28 April 2017 the National Wireless Carriers responded to these requests for disclosure and further information.

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 requests for further responses to interrogatories, the requirements of section 76 of the Rules of Procedure 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 Freedom Mobile, Eastlink, Videotron and Ice Wireless, along with responses submitted by the National Wireless Carriers and considers that additional disclosure and further responses are necessary in order for parties to be able to intervene meaningfully and for the Commission to obtain a comprehensive record.

Based on the review of the requests and responses, Commission staff considers that the parties listed in the Attachment are to disclose and to provide further response to the specified information on the public record, or file it with the Commission, as the case may be, by 14 June 2017.

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 costing and rates for 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 (2)

Distribution list:
Bell Mobility Inc.,
Rogers Communications Canada Inc.; Nathan Jarrett,
TELUS Communications Company,
Videotron s.e.n.c.,
Bragg Communications Incorporated (Eastlink),
Globalive Wireless Management Corp.,;
Freedom Mobile Inc., Ed Antecol,
MTS Inc.,
Saskatchewan Telecommunications,
Ice Wireless Inc.,
Canadian Network Operators Consortium Inc.
Public Interest Advocacy Centre (PIAC)
Corridor Communications, Inc.
Benjamin Klass,
Vaxination Informatique,



Bell Mobility

  1. Bell Mobility (CRTC) 20Dec16-3(a) TN1B & 2: Bell Mobility is to disclose on the public record the first 10 words and the last 9 words of the confidential section on page 7 of 22 of its response filed in confidence.
  2. Bell Mobility (CRTC) 20Dec16-5 TN1B & 2: Bell Mobility is to disclose on the public record the column Spectrum and Other Licenses in Note 14 b) Intangible Assets – Bell Mobility Segment in the Attachment to its revised response.


  1. Rogers (CRTC) 20Dec16-3b: Rogers is to disclose on the public record the confidential information in the response to request for information Rogers (CRTC) 20Dec16-3b.
  2. Rogers (CRTC) 20Dec16-9c: Rogers is to disclose on the public record the confidential information in the response to request for information Rogers (CRTC) 20Dec16-9c.



  1. TELUS(CRTC) 20Dec16-3(c) : TELUS is to provide a response to:
    1. For all existing wireless facilities included in the cost study, provide the Net Book Value (NBV) and the corresponding depreciation and amortization at end-of-year 2015, and associated remaining life estimates (this should not be the proposed life estimate for wireless facilities) in Table 1 in Attachment 2 (add lines as necessary to include all existing wireless facilities). Further, provide the supporting documentation that explains how the NBV, the corresponding depreciation and amortization, and the associated remaining life estimates were estimated. If the requested information is not available on an individual wireless equipment basis, provide the same information on an aggregated basis, as available.
  2. TELUS(CRTC) 20Dec16-3(e): TELUS is to provide a revised cost study reflecting the following changes in assumptions:
    1. Replace the capital cash flow and the associated life estimate at the start of the cost study for each of the existing facilities in the cost model with the associated NBV value and remaining life estimate provided in Table 2 in Attachment 2.
    2. Replace the Spectrum capital cash flow at the start of the cost study with the value provided in the column titled “Present Worth of the remaining value of spectrum asset” in the table provided in the response to CRTC 17Jun16-1. With respect to capital characteristics, assume rectangular survivor curve patterns and no capital increase factors (CIFs) and productivity improvement factors (PIFs).

    If the information is not available at the disaggregated level, provide the revised cost study using the most available and reliable data, at the aggregated level, for TELUS’ wireless facilities.

  3. TELUS(CRTC) 20Dec16-1: TELUS is to provide an updated response including:
    1. Revised cost and rates in $/Megabytes (MB) for data, $/minute for voice, and $/text for SMS using the economic parameters provided in current Appendix V of the company’s Economic Studies Manual, and that it incorporates the responses to all requested interrogatories, where applicable, using the format of the tables used to provide:
      1. Price Floor Test - Total Present Worth of Revenues and Cost within Study Period,
      2. Price Floor Test - Revenues and Costs per Megabytes, per minute and per Text Message,
      3. Demand Estimate over the study period including the start study demand and
      4. Detailed Summary of Costs Causal to Service and Demand respectively.
    2. for each year of the revised cost study in response to a) above, the capital cash flows for all wireless facilities associated with the RAN, Backhaul, and Core Network.
    3. a copy of the updated economic model (including all associated files required to run the model) that incorporates the responses to all requested interrogatories, where applicable.
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