ARCHIVED - Telecom Procedural Letter Addressed to Mr. Robert Knowlton (Frontline Broadband Inc.)

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Ottawa, 25 September 2018

Our reference: 8740-F53-201806309


Mr. Robert Knowlton
Chief Financial Officer,
Frontline Broadband Inc.
1 Toronto Street, Suite 805
Toronto, Ontario  M5C 2V6

Re: Frontline Broadband Inc. Tariff Notice 1 – Proposed Access Services Tariff

Dear Sir:

On 16 August 2018, the Commission received an application by Frontline Broadband Inc. (Frontline) under Tariff Notice 1, proposing the introduction of its Access Services Tariff.

Commission staff is continuing its analysis of this application.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.

Frontline is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 5 October 2018.


Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Joseph Cabrera, CRTC, 819-934-6352,

Attach. (1)

Request for Information – Frontline Broadband Inc. Tariff Notice 1

In a letter, dated 6 August 2018, Frontline Broadband Inc. (Frontline) notified the Commission of its fulfilment of its obligations for entry as a competitive local exchange carrier (CLEC). In addition, Frontline requested that the Commission recognize it as a Type III CLEC.

In the Appendix to the letter, Frontline indicated that it would rely on its underlying local exchange carrier (LEC) to meet its CLEC obligation for interexchange equal access.

Part C - Interconnection with Interexchange Service Providers (IXSPs) of Frontline’s proposed CLEC tariff, submitted on 16 August 2018, reflects that IXSPs will interconnect directly with Frontline rather than through an underlying carrier. In addition, Part B - Interconnection with Local Exchange Carriers and Part D - Interconnection with Wireless Service Providers of the proposed CLEC tariff reflect direct interconnection with local exchange carriers (LECs), and wireless service providers (WSPs) respectively. Direct interconnection with these types of service providers imply that Frontline will operate as a Type I CLEC.

  1. Identify whether Frontline will use an underlying carrier to meet its CLEC obligations for any of interexchange equal access, LEC interconnection, and WSP interconnection.  
    1. If not, Frontline should revise its notification letter to reflect that it will operate as a Type I CLEC.
    2. If so, Frontline should revise its tariff to reflect use of an underlying carrier, identifying the underlying carrier. (see Note)

Note: For an example of tariff wording for use of an underlying carrier for interconnection with LECs and WSPs, Frontline can reference previous applications by Type IV carriers. For example the application of GB Tel in 2015. Note that as a Type IV carrier, GBTel’s tariff does not reflect the obligation to provide equal access to IXSPs, whereas a Type III CLEC’s tariff must reflect that obligation.

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