ARCHIVED - Telecom Procedural Letter Addressed to the Distribution List

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Ottawa, 16 October 2017

Our reference: 1011-NOC2017-0259



Re: Reconsideration of Telecom Decision 2017-56 regarding final terms and conditions for wholesale mobile wireless roaming service

Dear Madam, Sir:

Pursuant to paragraph 12 of Telecom Notice of Consultation CRTC 2017-259, attached are requests for information in that proceeding. The parties identified in the distribution list are to file responses to the questions set out in the attachment by 30 October 2017. These submissions must be received, not merely sent, by that date.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.


Original signed by

Philippe Kent
Director, Competition & Emergency Service Policy
Telecommunications Sector

c.c.:  Adam Mills, CRTC,
Jeremy Lendvay, CRTC,

Distribution List

Aaron Messer:;
Anthony Humphreys:;
Anthony Stadnyk:  
Bell Mobility:;
Brian Murrell:;  
Canadian Cable Systems Alliance Inc.:;
Canadian Wireless Telecommunications Association:;
CNOC Regulatory: ;
Coalition pour le service 9-1-1 au Québec:;
Cogeco Cable Inc.:
Darren Parberry:;
Déry Télécom inc.:;
Denver Gingerich:;
Distributel Communications Limited:; Eastlink:
Execulink Telecom Inc.:;
Government of Saskatchewan:;
Ice Wireless Inc.:;
Internet Society Canada Chapter:;
Jason Fohring:;
Jordan Bowness:;
Joseph Floyd:;
Justin Cate:;
Province of British Columbia:;
Public Interest Advocacy Centre:;
Quantum Republic Inc.:;
Quebecor Media Inc. (Videotron):
Rogers Communications Canada Inc.:;
Shaw Communications Inc.:
Saskatchewan Telecommunications:
SSi Micro Ltd:
Stephen Weber:;
TELUS Communications Company:
TNW Wireless Inc.:;
Tucows Inc.:
Xplornet Communications Inc.:


Requests for information

To all parties:

  1. In its submissions, Rogers proposed that if the Commission were to mandate access to the radio access networks (RANs) of the national wireless carriers for alternative wireless service providers (AWSPs), then the following restrictions should apply: (1) AWSPs should be Canadian carriers that own and operate mobile networks (including licensed spectrum and RAN), (2) Mandated access for AWSPs should only apply to carriers’ 3G networks, (3) AWSPs should only be permitted to offer and provide retail mobile wireless services to qualifying low-income Canadians, (4) there should be a usage cap of 50MB/subscriber/month, and (5) the wholesale rate for the 50 MB should be $3.75. Various parties proposed alternative conditions to any additional form of mandated access that may be introduced.
    1. Provide your views with respect to the appropriateness of the conditions associated with the AWSP access to the RANs of the national wireless carriers proposed by Rogers. How would these proposed conditions address the considerations identified in Order in Council 2017-0557, especially with respect to affordability and investment in wireless infrastructure?
    2. Provide your views as to whether there is any functional difference between how AWSPs would access the RANs of the national wireless carriers versus how roaming carriers currently access the RANs of the national wireless carriers. If there is no functional difference, should the rates associated with potential AWSP access differ from those for roaming on the networks of the national wireless carriers? Explain why or why not with economic rationale.
  2. In Telecom Regulatory Policy 2015-177 the Commission determined that GSM-based wholesale roaming and MVNO access provided by Bell Mobility, Rogers, and Telus are essential, and therefore required wholesale roaming service to be provided under regulated rates, terms, and conditions. In the same decision the Commission considered that if it were to mandate wholesale MVNO access at that time it would significantly undermine wireless carriers’ investments in spectrum and wireless networks, and for these reasons determined that it was not appropriate to mandate wholesale MVNO access.
    1. Could the Commission mandate access to the RANs of facilities-based wireless carriers for AWSPs without re-applying the essentiality test performed in Telecom Regulatory Policy 2015-177? Provide supporting evidence for your view.
    2. Can the existing roaming tariff be modified to accommodate AWSP access, or is a separate tariff required?
  3. Order in Council 2017-0557 indicates that innovative business models and technological solutions, such as those offered by AWSPs, can result in more meaningful choices for Canadians with low income. The AWSP service model generally relies on data networks (i.e. a combination of Wi-Fi and mobile wireless data), with the expectation that customers would rely on Wi-Fi to the greatest extent possible
    1. If wireless carriers were to introduce a data-only retail mobile wireless service plan for use on mobile phonesFootnote1 , comment on how this would address, in whole or in part, the considerations identified in Order in Council 2017-0557, especially with respect to affordability and investment in wireless infrastructure.
    2. If the Commission were to determine that the availability of such plans is in the public interest, comment on how the Commission could impose a regulatory obligation on wireless carriers requiring them to offer and provide such plans. Could such an obligation be imposed under section 24 of the Telecommunications Act or by some other method?
    3. What reasonable service parameters (e.g. data allowance) should apply to a data-only retail mobile wireless service plan for use on mobile phones in order to ensure that such plans address the challenges faced by Canadians with low household income?
  4. With respect to the provision of 9-1-1 service, in the event that the Commission mandated access to the RAN of wireless carriers for AWSPs:
    1. How should 9-1-1 service be implemented? Should AWSPs be required to provide 9-1-1 service that is the same as what is provided by wireless carriers?
    2. Are there any technical limitations that would impact the ability of AWSPs to provide 9-1-1 service?
    3. Should the 9-1-1 requirements for nomadic VoIPFootnote2 , including notification requirements, apply to AWSPs?
  5. Given that the services provided by AWSPs would generally require:  (a) a smartphone and (b) access to a broadband internet connection to leverage Wi-Fi first access, provide any evidence that supports the view that such services would be accessible and beneficial to Canadians with low household income.

    To Bell Mobility, Eastlink, Freedom Mobile, Ice Wireless, Rogers, SaskTel, TELUS and Videotron:

  6. Does your company or any of your flanker brands offer a data-only retail mobile wireless service plan for use on mobile phones (i.e. excluding plans:  (i) that are made available for customers who self-identify as having a disability or (ii) that are intended to be used with LTE Hubs/USB modems)? If you do, provide a list of all such plans including the following details: (1) price, (2) price per GB, and (3) data allotments available. If you do not provide such a plan, explain why not.
  7. How do you promote your lowest-cost plans to Canadians with low household income?
  8. Identify any federal, provincial or territorial programs you are aware of, which support the affordability of mobile wireless services for Canadians with low household income. Do you offer, or plan to offer, any special mobile wireless plans that are supported by this funding? If you do have such service plans, provide the details (e.g. price, data/minutes included).
  9. In its submission, the Public Interest Advocacy Centre (PIAC) indicated that there may be risks associated with current network sharing agreements in Canada, particularly between Bell and Telus. PIAC also referenced an OECD reportFootnote3 that suggested that network sharing among carriers can result in less network capacity being available, and that this can lead to a reduction in the incentives for carriers to supply capacity to MVNOs and price aggressively at the retail level:
    1. In your view, do any network sharing arrangements currently in place in Canada: (i) adversely affect network capacity, (ii) impact the affordability of retail mobile wireless services, (iii) impede the entry into the Canadian market of MVNOs that are not affiliated with Canadian facilities-based wireless carriers, or (iv) impede the level of facilities-based competition?

    To Bell Mobility, Telus:

  10. Provide all assumptions and data that you used to calculate the Herfindahl-Hirschman Index (HHI) for the Canadian market. Were affiliated companies and flanker brands counted as separate entities for the purposes of this calculation? If they were, recalculate the HHI for the Canadian market where each wireless carrier’s market share is combined with the market share of its affiliated companies and flanker brands as a single entity.
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