ARCHIVED - Telecom procedural Letter adressed to Philippe Gauvin (Bell Canada) and Howard Slawner (Rogers Communications Canada Inc.)

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Ottawa, 26 July 2019

Our reference: 8622-R28-201902940


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

Mr. Howard Slawner
VP – Regulatory, Telecom
Rogers Communications Canada Inc.
350 Bloor Street East
Toronto, ON  M4W 0A1

RE: Rogers Communications Canada Inc. Part 1 Application against Bell Canada concerning the Routing of Rogers-originated Toll Free Traffic destined to Bell’s Toll Free Telephone Numbers

Dear Sirs:

On 29 April 2019, the Commission received an Application from Rogers Communications Canada Inc. (Rogers), requesting that the Commission grant the following relief:

  1. That the Commission confirm that Rogers is not mandated to route one-way Toll Free (TF) traffic destined to Bell Canada’s TF telephone numbers (TNs) over Rogers’ two-way Bill and Keep (B & K) trunks;
  2. That the Commission confirm that Bell Canada is mandated to deploy Toll trunks to Rogers’ switches in order to receive its TF traffic;
  3. That the Commission confirm that Rogers may invoice Bell Canada for its TF minutes as of 1 April 2019;
  4. That the Commission confirm that Rogers can bill Bell Canada as of 1 April 2019 for all TF-related charges, per Rogers’ competitive local exchange carrier (CLEC) access services tariff (AST).

In a letter dated 17 July 2019, Commission staff requested Bell Canada and Rogers to submit additional information to the Commission by 29 July 2019.

In a letter dated 24 July 2019, Bell Canada requested that the deadline for filing its response to the staff letter be extended from 29 July 2019 to 29 August 2019. Bell Canada cited the following reasons for its request:

  1. The information requested in question #2 is not readily available and will require a manual pull of the data, as well as an assessment of the reliability of the data gathered.
  2. Regarding the Rogers-originating TF traffic volume data requested in sub-questions #2.a and #2.b, Bell Canada submitted that while it has direct visibility into the traffic terminating to third-party IXC toll trunks, it does not have an established process to readily identify the origin of this traffic. Bell Canada submitted that it is therefore attempting to gather the information manually, a process which the company anticipates will require a few weeks.
  3. The answering process for question #2 is sequential; therefore, Bell Canada cannot address the financial data requested in sub-question #2.c of the staff letter until the company has derived totals for sub-questions #2.a and #2.b.
  4. The same subject matter experts are involved in gathering the information relevant to questions #1 and #2, and thus it is not practical to respond to question #1 in isolation before Bell Canada’s proposed deadline for all responses.

On 25 July 2019, Rogers responded to Bell Canada’s extension request. Rogers submitted that while it did not oppose Bell Canada’s request, it urged the Commission to collect the information requested as soon as reasonably possible and rule expeditiously on the matter raised in Rogers’ application.

Commission staff is of the view that granting Bell Canada’s request would benefit the proceeding by enabling the Commission to gain a more fulsome record. As well, given the challenges described by Bell Canada in assembling the information requested, Commission staff is of the view that Bell Canada’s requested extension is therefore reasonable under the circumstances. Having regard to all the above, Commission staff is of the view that granting the requested extension would be in the public interest.

However, staff is also of the view that in the interest of fairness, the deadline extension proposed by Bell Canada should also be provided to Rogers. Therefore, the deadline for both Bell Canada and Rogers to file their respective responses to the above-mentioned Commission staff letter is extended to 29 August 2019.


Original Signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications sector

cc.:  Rudy Rab, CRTC,
Jeff Brownlee, Canadian Network Operators Consortium Inc.,
Christopher Hickey, Distributel Communications Ltd.,
Jean-François Dumoulin, Iristel Inc.,
Dennis Béland, Québecor Média inc.,
John MacKenzie, TELUS Communications Inc.,

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