Telecom - Commission letter addressed to the Distribution list

Ottawa, 10 December 2019

Our reference: 8621-C12-01/08


BY EMAIL


Distribution list


RE: CRTC Interconnection Steering Committee – Non-consensus report 1540RE04 on the status of third-party Internet access (TPIA) installation orders and trouble tickets, and related process guidelines - Progress Reports


Dear Madams/Sirs:

In CRTC Interconnection Steering Committee – Non-consensus report 1540RE04 on the status of third-party Internet access installation orders and trouble tickets, and related process guidelines, Telecom Decision CRTC 2018-357, dated 7 September 2018 (Decision 2018-357), the Commission, among other determinations, determined that Bragg Communications Inc., carrying on business as Eastlink (“Eastlink”), Cogeco Communications Inc. (Cogeco), Rogers Communications Canada Inc. (Rogers), Shaw Cablesystems G.P. (Shaw) and Vidéotron Ltd. (Vidéotron) (collectively referred to as the Cable Carriers) were to implement, at a minimum, next day batch reporting and to report to the Commission within six months of the publication of the final 1540GLTPIASOTT1 – Process Guidelines for TPIA Service Orders and Trouble Tickets, Version 1 (the Guideline) on:

The final Guideline was published on 20 February 2019, resulting in reporting to the Commission by 20 August 2019. 

On 20 August 2019, the Commission received progress reports from Eastlink, Rogers, and Vidéotron. Eastlink, Rogers, and Vidéotron submitted updates on their respective progress in implementing the consensus items proposed in the Guideline as well as confirmation that each had implemented, at a minimum, next day batch reporting. However, Eastlink did not provide any information regarding any technical or economic constraints of same day or real time reporting.

On 11 October 2019, the Commission received a progress report from Cogeco. Cogeco submitted that numerous other activities and filings all took precedence since August 2019, leaving little time for the more day-to-day regulatory filings resulting in their delay in filing their status report.

Cogeco submitted their progress updates on implementing the consensus items in the Guideline and confirmed that Cogeco was assessing which of the two approaches to take (i.e., implementing, at a minimum, next day batch reporting and implementing same day or near real-time batch reporting). Cogeco indicated that it expects to be in a position to implement one of the two solutions by the end of March, 2020 at the latest.

Shaw indicated that the Chair of the Ad Hoc 1540 Wholesale High-speed Access Working Group did not provide notification that the Guideline had been published until the working group session in June 2019. Shaw was of the view that this notification resulted in a requirement to report to the Commission by December 2019.

Instances of non-compliance with Commission decisions, including reporting deadlines and the provision of complete reports, are of concern to Commission staff. Commission staff notes that the Commission has various recourse mechanisms (e.g., imposition of administrative monetary penalties) to address cases of non-compliance with Commission decisions in order to promote compliance with the Telecommunications Act and Commission decisions

In order to assist in the review of the outstanding and submitted progress reports, Eastlink, Cogeco, and Shaw are requested to provide responses to their following respective requests for information by 13 January 2020.

Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing Implementation
Telecommunications Sector

c.c. Matthew Alexander, CRTC, matthew.alexander@crtc.gc.ca
William Lloyd, CRTC, william.lloyd@crtc.gc.ca


Attach. (2)


Distribution List

bergeron.alain@oricom.ca, Matthew.Alexander@crtc.gc.ca, andrea.heller@sasktel.com, akaplanmyrth@teksavvy.ca, anne.mcmillan@distributel.ca, Barry.Choi@rci.rogers.com, bianca.sgambetterra@cogeco.com, Charles.Pronovost@videotron.com, chris.kellett@eswg9-1-1.ca, dmckeown@viewcom.ca, David.Watt@rci.rogers.com, regaffairs@quebecor.com, ddolan@teksavvy.ca, Diane.Gilbert@rci.rogers.com, don.grant@distributel.ca, Dorothea.Schramm@rci.rogers.com, Erich.Baumgartner@rci.rogers.com, edelduca@comwave.net, esther.snow@sjrb.ca, Graham.LeGeyt@sjrb.ca, jason.gatelaro@videotron.com, Jocelyn.Kearney@sjrb.ca, John.Li@sjrb.ca, martha.facey@execulink.com, Leonard.Eichel@cogeco.com, Marielle.Wilson@corp.eastlink.ca, Martin.PerreaultING@videotron.com, michel.messier@cogeco.com, Michelle.Dupuis@telus.com, pmisur@teksavvy.ca, patrick.desy@quebecor.com, palang@shaw.ca, rocca@start.ca, robm@clearcable.ca, rob.olenick@tbaytel.com, sam.glazer@sympatico.ca, Serena.Xie@rci.rogers.com, Simon-Pierre.Olivier@fidomobile.ca, steve.hardy@videotron.com, Thomas.Grasham@rci.rogers.com, Jason.Li@sjrb.ca, dmackwood@teksavvy.ca, Nathan.Jarrett@rci.rogers.com, KMitchell@teksavvy.ca, Gerry.Thompson@rci.rogers.com, cjpcopeland@tacitlaw.com



Request for information – Eastlink

  1. Refer to Eastlink’s TPIA Process Guidelines Progress Report, dated 20 August 2019, where Eastlink did not comment on the technical or economic constraints to providing TPIA Customers with same day or near real-time batch reporting, including supporting rationale and a timeline for when same day or near real-time batch reporting can be provided to TPIA Customers.
    1. Provide supporting rationale why Eastlink did not comment on the technical or economic constraints to providing TPIA Customers with same day or near real-time batch reporting, including supporting rationale and a timeline for when same day or near real-time batch reporting can be provided to TPIA Customers.
    2. Comment on the technical or economic constraints to providing TPIA Customers with same day or near real-time batch reporting, including supporting rationale and a timeline for when same day or near real-time batch reporting can be provided to TPIA Customer.

Request for information – Cogeco

  1. Refer to Cogeco’s State of progress report, dated 11 October 2019, where Cogeco indicated that regarding the non-consensus item of reporting on the status of service orders, Cogeco is still assessing which of the two approaches to take. Cogeco expects to be in a position to implement one of the two solutions by the end of March, 2020 at the latest.
    1. Provide supporting rationale why Cogeco has not implemented, at a minimum, next day batch reporting as directed by the Commission in Decision 2018-357.
    2. Provide supporting rationale why Cogeco requires an extension to implement one of the two solutions by the end of March, 2020 at the latest.
    3. Comment on the technical or economic constraints to providing TPIA Customers with same day or near real-time batch reporting, including supporting rationale and a timeline for when same day or near real-time batch reporting can be provided to TPIA Customers.

Request for information – Shaw

  1. Refer to Decision 2018-357, where the Commission, among other determinations, determined that:
    1. At a minimum, next day batch reporting to be implemented by all Cable Carriers within six months of the publication of the final Guideline.
    2. Cogeco, Eastlink, RCCI, Shaw, and Videotron to report to the Commission, within six months of the publication of the final Guideline, on (i) the state of progress in implementing the non-consensus item in the Guideline; and (ii) any technical or economic constraints to providing TPIA Customers with same day or near real-time batch reporting, including supporting rationale and a timeline for when same day or near real-time batch reporting can be provided to TPIA Customers
    3. Cogeco, Eastlink, RCCI, Shaw, and Videotron to report to the Commission, within six months of the publication of the final Guideline, their progress in implementing the consensus items proposed in the Guideline.
      1. Provide supporting rationale why Shaw has not reported to the Commission regarding the above three items within six months of the publication of the final Guideline.
      2. Provide the date that Shaw proposes to report to the Commission with supporting rationale.
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