ARCHIVED - Telecom Commission Letter Addressed to Philippe Gauvin (Bell Canada)

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Ottawa, 8 November 2018

Our reference: 8640-M59-201805631


Mr. Philippe Gauvin
Assistant General Counsel
Bell Canada
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4

Re: Bell MTS – Application for forbearance from the regulation of business local exchange services in various Manitoba exchanges – competitor quality of service results

Dear Sir:

The Commission received a Part 1 application from Bell MTS Inc. (Bell MTS), dated 31 July 2018, in which the company requested forbearance from the regulation of business local exchange services in 24 exchanges in Manitoba. Shaw Telecom G.P. (Shaw) and Westman Communications Group (Westman) submitted interventions, dated 28 August and 7 September 2018, respectively.

The Commission received a revised application from Bell MTS, dated 14 September 2018, which included several changes. Footnote1

In order to provide all parties an adequate opportunity to comment on the revised application, the deadlines associated with the application were extended. There were no additional interventions and the record closed on 5 October 2018.

Commission staff has reviewed the revised application and considers it to be incomplete – specifically regarding Bell MTS’s competitor quality of service (CQ of S) results.

As set out in Telecom Decision 2006-15, Footnote2 among the criteria an ILEC must satisfy before local forbearance may be granted is a requirement that the ILEC demonstrate that during a six-month period, beginning no earlier than eight months before its application and ending any time before the Commission’s decision respecting the application,

  1. it met, on average, the quality of service standard for each indicator set out in Appendix B of Telecom Decision 2006-15, as defined in Telecom Decision 2005-20, Footnote3 with respect to the services provided to competitors in its territory,and
  2. it did not consistently provide any of those competitors with services below those quality of service standards.

Bell MTS submitted its CQ of S results for the six-month period ending on 31 May 2018 as an attachment to its application, under the title “ILEC (Corporate) Forbearance Indicators.”

Commission staff notes that the CQ of S results submitted on the record of this proceeding appear to be missing information about the quality of service provided to some of Bell MTS’s competitors, based on a comparison with Bell MTS’s fourth quarter 2017 CQ of S results.

In order for the application to be deemed complete, Bell MTS is to submit its CQ of S results for all competitors in its territory. If it is unable to do so, the company is to explain why this is not possible. Bell MTS is to serve its response on all members of the distribution list.

Any interested person may file an intervention within 10 days of the date of Bell MTS’s submission, and Bell MTS may provide a reply within 5 days of the date any comments are received.


Original signed by

Philippe Kent
Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c.:  Paul Cowling, Shaw,
S.J. (Shep) Kastra, Westman,
CLECs and Proposed CLECs
Mohsin Tahirkheli, CRTC,

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