ARCHIVED - Telecom Procedural Letter Addressed to Various Parties
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Ottawa, 21 January 2019
Our reference: 1011-NOC2017-0450
Dear Madam, Sir,
Re: Apportioning of costs in the Public Interest Advocacy Centre’s application for costs arising from the review of the reseller registration obligation, Telecom Notice of Consultation CRTC 2017-450
On 15 December 2017, the Commission issued a call for comments on which types of non-carriers (resellers) should be exempt from the obligation to register with the Commission prior to receiving telecommunications for resale from Canadian carriers or other resellers.
On 1 March 2018, the Commission circulated a procedural letter to various parties, including those who intervened in the proceeding initiated by TNC 2017-450 as well as to distribution lists maintained by the Commission. The letter included five questions to all recipients (with an additional question to TELUS Communications Inc.). The Commission received various submissions in response. Some parties submitted responses to the Commission’s questions, as required, but did not otherwise participate voluntarily in the proceeding.
On 8 May 2018, the Commission received an application for costs from the Public Interest Advocacy Centre (PIAC). In its costs application, PIAC suggested that its costs should be apportioned in the following manner:
- Half of its costs should be divided equally among Queen’s University, FCA Canada Inc., and IBM Canada Ltd.;
- The remaining half should be paid by TELUS Communications Inc., Bell Canada, and Rogers Communications Canada Inc. in proportion to their telecommunications operating revenues (TORs).
Commission staff notes that the Commission’s general practice is to apportion costs based on the TORs of the parties to the proceeding as well as considering the usual costs award practices and procedures set out in Telecom Regulatory Policy CRTC 2010-963.
Commission staff further notes that, in the proceeding, many companies intervened that are not telecommunications service providers and do not have significant, if any, TORs.
To obtain the parties’ views on possible costs apportionment, Commission staff has attached requests for information. Parties copied on this correspondence are to provide responses to the requests for information, to be filed and served on the parties copied on this correspondence by 31 January 2019. The responses will be available for all parties on the Commission’s website. Parties copied on this correspondence may file comments on the responses to the requests for information, to be filed and served on the parties copied on this correspondence by 5 February 2019.
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
Public Interest Advocacy Centre, firstname.lastname@example.org & email@example.com
British Columbia Broadband Association (BCBA), firstname.lastname@example.org
FCA Canada Inc., email@example.com
Geotab Inc., firstname.lastname@example.org
Independent Telecommunications Providers Association, email@example.com
IBM Canada Ltd., firstname.lastname@example.org
University of Alberta, email@example.com
Canadian Network Operators Consortium Inc., firstname.lastname@example.org
Québecor Média inc., email@example.com
TELUS Communications Inc., regulatory.affairs@TELUS.com
Queen’s University, firstname.lastname@example.org & email@example.com
Cogeco Communications Inc., firstname.lastname@example.org
The Toronto Internet Exchange, email@example.com
Coalition pour le service 9-1-1 au Québec, firstname.lastname@example.org
Cybera Inc., email@example.com
McLean & Kerr LLP, firstname.lastname@example.org
Communications Distributors Inc., email@example.com
Steven Shearer, firstname.lastname@example.org
Verizon Canada ltd., email@example.com
Bell Canada, firstname.lastname@example.org
Shaw Communications Inc., email@example.com
676766 Ontario Ltd operating as “KWIC Internet”, firstname.lastname@example.org
Thomson Reuters Canada Limited, email@example.com
SSI Micro Ltd., firstname.lastname@example.org
Sprint International Communications Canada ULC, email@example.com
094206 Ontario Ltd operating as "Ruralwave”, firstname.lastname@example.org
Columbia Basin Broadband Corporation, email@example.com
Pulsar360 Inc., firstname.lastname@example.org
Core Broadband Inc., email@example.com
Silo Wireless Inc., firstname.lastname@example.org
Saskatchewan Telecommunications, email@example.com
Microsoft Corporation, firstname.lastname@example.org
Rogers Communications Canada Inc., email@example.com
Colt Technology Services LLC, firstname.lastname@example.org
West Telecom Services LLC, email@example.com; firstname.lastname@example.org
BullsEye Telecom Inc., email@example.com
If the Commission decided to award costs in this proceeding, should the costs be apportioned solely among the participating telecommunications service providers (TSPs) in proportion to each TSPs’ telecommunications operating revenues? If yes, should those TSPs that only responded to the 1 March 2018 procedural letter also be included in the apportionment?
Indicate, with supporting rationale, whether or not you support this approach to apportionment of costs in this proceeding.
If you do not support the appropriation models contemplated in question 1, which appropriation model would you propose and why?
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