ARCHIVED - Telecom Commision Letter addressed to the Distribution List

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Ottawa, 13 October 2017

Our references:


Distribution list

RE:   Follow-up to Telecom Decision CRTC 2016-379 – Request to extend process deadlines and clarify process

Dear Madams/Sirs:

The Commission received a letter, dated 6 October 2017, from Bell Canada requesting to extend the process deadline set out in the Commission staff letter, dated 17 August 2017, for the tariff applications related to the disaggregated wholesale high-speed access (HSA) services. Specifically, Bell Canada requested that the Commission extend the reply deadline from 16 October to 30 October 2017. Bell Canada submitted that its extension request is reasonable given the number of issues raised and the extensive set of comments filed by Canadian Network Operators Consortium Inc. (CNOC) on the aggregated and disaggregated wholesale HSA service tariff filings.

The Commission is in receipt of letters, dated 10 October 2017, from Cogeco Communications Inc., Quebecor Media Inc., on behalf of Videotron G.P., Rogers Communications Canada Inc. (RCCI), TELUS Communications Company (TCC) supporting Bell Canada’s extension request, and from CNOC, which did not oppose Bell Canada’s extension request.

In its letter, dated 10 October 2017, CNOC did not take a position on Bell Canada’s extension request, but requested that the Commission provide clarification regarding whether any party may file reply comments to the interventions filed on 22 September 2017. CNOC submitted that procedural fairness requires that any party be allowed to file reply comments. By letter, dated 12 October 2017, CNOC provided its response to TCC arguments proposed in a separate process and reiterated its request that the Commission clarify that any party be allowed to file reply comments.
With respect to Bell Canada’s extension request, Commission staff considers that, in the circumstances, a two week extension to the reply comments is reasonable as it will allow for adequate time to provide fulsome responses to numerous issues.

With respect to CNOC’s request for clarification, Commission staff notes that in the letter, dated 1 August 2017, which established procedural timelines for the tariff filings under consideration, there was an inadvertent error stating that any party may file a reply, which was corrected in the Commission staff letter, dated 17 August 2017.

In addition, Commission staff notes that the established rules of practice and procedure allow any interested person with an opportunity to comment on an application. An intervention may be filed by someone who supports the application as it may be filed by someone that opposes an application. The fact that an intervenor has taken a position that is not supported by another intervenor does not result in the need to provide the latter with a right of reply. Procedural fairness requires that persons with an interest in a proceeding are provided with an opportunity to properly acquaint themselves with the issues under consideration and make their position known on these issues. The procedures set out in the Commission’s rules of practice and procedure, as applied to the individual tariff applications under consideration, properly provide all interested persons with this opportunity.

The Commission is in receipt of a letter, dated 11 October 2017, from CNOC requesting that the Commission direct RCCI to provide additional information on its proposed cost adjustments and set a process for comment and reply to comment.

Commission staff considers that RCCI’s proposed cost adjustments will be addressed in the upcoming request for information process. Parties will have the opportunity to file comments on the matter in that process.

Commission staff hereby informs all interested persons that the procedural date for the filing of reply comments regarding the tariff applications related to disaggregated wholesale HSA services (outlined above and listed in the attachment) is modified as follows:

A Commission staff letter providing additional information on process concerning requests for information will be sent out in due course.

Please contact Tom Vilmansen ( at (819) 997-9253 or myself ( at (819) 953-5414 should you have any questions in regards to this letter.

Original signed by Tom Vilmansen for

Lyne Renaud
Director, Competitor Services and Costing Implementation
Telecommunications Sector

c.c.: Tom Vilmansen, CRTC, 819-997-9253,

Attach. (1)

Distribution List ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; ;

Bell Canada TN 7522, 7522/A: 8740-B2-201700055 - Disaggregated Broadband Service (DBS)
Bell Canada TN 7524, 7524/A: 8740-B2-201700542 - Disaggregated Broadband Service (DBS) Meet-me Point (DMMP) Service
Bell Canada TN 7534: 8740-B2-201703463 - Disaggregated Broadband Service (DBS) Bonded FTTN Access
Cogeco TN 56: 8740-C6-201700097 - Disaggregated Third Party Internet Access (TPIA) services
Cogeco TN 57: 8740-C6-201701392 - Disaggregated TPIA services over EPON/FTTH
RCCI TN 48: 8740-R28-201700071 - Disaggregated Third Party Internet Access (TPIA) services
Videotron TN 53: 8740-V3-201700063 - Disaggregated Third Party Internet Access (TPIA) services

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