ARCHIVED - Telecom Commission Letter Addressed to Tiéoulé Traoré (Canadian Wireless Telecommunications Association )

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Ottawa, 9 May 2018

Our reference: 8662-T66-201801514 and 4762-189

BY EMAIL

Tiéoulé Traoré
Manager, Government Relations
Canadian Wireless Telecommunications Association
80 Elgin Street
Ottawa, ON
Email: ttraore@cwta.ca

Re: TELUS Communications Inc. - Application to Review and Vary Telecom Order 2017-424

Dear Mr. Traoré,

On 15 March 2018, the Commission received an application from TELUS Communications Inc. (TCI) to review and vary Telecom Order 2017-424 pursuant to s. 62 of the Telecommunications Act.) ^Footnote1 By letter dated 16 April 2018, the Canadian Wireless Telecommunications Association (CWTA) filed its answer. TCI submitted its reply on 26 April 2018.

The purpose of this letter is to request additional information from the CWTA regarding TCI’s review and vary application.

Basis for determining costs allocation

In its comments, the CWTA noted that wireless service providers are among the entities that it represents.) ^Footnote2 The CWTA also submitted the following:

If the Commission were to depart from its long standing practice, it would be required to determine the relative interest that some CWTA members had with respect to the proceedings in order to determine an appropriate percentage of costs that should be allocated to CWTA vis a vis other participants in the proceedings. We submit that it would be impossible for the Commission to make such a determination on any fair or principled basis. TELUS’ suggestion that the allocation of costs to individual members should be left to CWTA’s internal processes does not address this threshold issue of what share of costs should properly be awarded to CWTA.) ^Footnote3

In light of the above submissions, please comment on the following:

The Commission’s general practice is to allocate the responsibility for payment of costs among costs respondents based on their telecommunications operating revenues (TORs)) ^Footnote4 as an indicator of the relative size and interest of the parties involved in the proceeding.
1. If the CWTA were named a costs respondent, comment on whether or not it is appropriate for the Commission to allocate costs to the CWTA based on the TORs of its members who are telecommunications service providers (TSPs).
2. If TORs are not an appropriate method to allocate any potential responsibility for payment of costs to CWTA, comment on how any potential costs may be allocated to the CWTA.
Regardless of the CWTA’s response to the above question, please provide the following:
1. A list of TSPs who were members of the CWTA during the proceeding that led to Telecom Decision 2016-479; and
2. In the above provided list, indicate which of these TSPs have TORs greater than $10 million annually. If necessary, the response to this request may be filed in confidence.) ^Footnote5