ARCHIVED - Telecom Procedural Letter Addressed to the Distribution list

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Ottawa, 13 October 2017

Our reference:  8740-B2-201606873, 8740-B2-201703447, 8740-C6-201606831, 8740-M59-201606980, 8740-R28-201606808, 8740-S22-201606823, 8740-S9-201606790, 88740-T66-201606815, 8740-V3-201606849, 8740-E17-201610262


Distribution list

RE:   Follow-up to Telecom Order CRTC 2016-396 and Telecom Order CRTC 2016-448 – 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 aggregated 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 11 October 2017, TCC opposed CNOC’s request that any party should have the right of reply and provided its reasons for limiting the right of reply to applicants. By letter, dated 12 October 2017, CNOC provided its response to TCC’s arguments 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 the numerous issues that have been raised.

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 aggregated 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 Abderrahman El Fatihi ( at (819) 953-3662 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.:  Abderrahman El Fatihi, CRTC,;
David Mah, CRTC,;
Ramin Adim, CRTC,

Attach. (1)

Distribution List

Lyne Renaud, CRTC,
Abderrahman El Fatihi, CRTC,;
David Mah, CRTC,;
Ramin Adim, CRTC,;
Bell Canada:;
MTS Inc.:;
Zayo Canada Inc.:;
Saskatchewan Telecommunications:;
TELUS Communications Company:;
Cogeco Cable Inc.:;
Quebecor Media Inc. (Videotron):;
Rogers Communications Canada Inc.:;;
Nathan Jarret:;;
Shaw Cablesystems G.P.:;
CNOC Regulatory: ;
TekSavvy Solutions Inc.:;
Vaxination Informatique:;
VMedia Inc.:;
Steve Sorochan:;
Darren Parberry:;
Marcus Schultze:;
Kathleen Turnsek:;
Tacit Law:;
Distributel Communications Limited:;

Bell Canada TN 7504: 8740-B2-201606873 - Aggregated wholesale HSA Service - Fibre to the Node (FTTN)

Bell Canada TN 7533: 8740-B2-201703447 - Aggregated wholesale HSA Service - Fibre to the Node (FTTN) - Bonded Access

Bell MTS TN 778/778A: 8740-M59-201606980 - Aggregated wholesale HSA Service - Fibre to the Node (FTTN)

TCC TN 512: 8740-T66-201606815 - Aggregated wholesale HSA Service - Fibre to the Node (FTTN)

SaskTel TN 329, 329/A: 8740-S22-201606823 - Aggregated wholesale HSA Service - Fibre to the Node (FTTN)

Cogeco TN 52, 52/A: 8740-C6-201606831 - Aggregated Third Party Internet Access (TPIA) services

RCCI TN 45, 45/A: 8740-R28-201606808 - Aggregated Third Party Internet Access (TPIA) services

Videotron TN 52, 52/A: 8740-V3-201606849 - Aggregated Third Party Internet Access (TPIA) services

Eastlink TN 37, 37/A: 8740-E17-201610262 - Aggregated Third Party Internet Access (TPIA) services

Shaw TN 26, 26/A: 8740-S9-201606790 - Aggregated Third Party Internet Access (TPIA) services

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