Telecom Notice of Consultation CRTC 2020-366-1

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Reference: 2020-366

Ottawa, 18 November 2020

Public record: 1011-NOC2020-0366

Call for comments regarding potential regulatory measures to make access to poles owned by Canadian carriers more efficient – Changes to procedure

Revised deadline for submission of interventions: 18 December 2020
Revised deadline for replies to interventions: 19 January 2021
Revised deadline for proposed requests for information: 3 February 2021

[Submit an intervention or view related documents]


  1. In Telecom Notice of Consultation 2020-366 (the notice), the Commission initiated a proceeding to examine potential regulatory measures to make access to poles owned by Canadian carriers more efficient (this proceeding).
  2. By letter dated 5 November 2020, TELUS Communications Inc. (TCI) requested that the deadline for filing interventions be extended from 30 November 2020 to 18 December 2020, with corresponding extensions to deadlines for replies and other steps in this proceeding. Various parties, including the Canadian Communication Systems Alliance; the Federation of Canadian Municipalities (FCM); the Independent Telecommunications Providers Association; Quebecor Media Inc., on behalf of Videotron Ltd. (Videotron); and Shaw Cablesystems G.P., filed letters in support of TCI’s request for extension.
  3. The British Columbia Broadband Association (BCBA) agreed with TCI that extending the deadline is necessary; however, it submitted that the deadline should be moved to 18 January 2021. The Canadian Electricity Association supported BCBA’s request. Connexion Matawinie argued that, due to its limited resources, the new deadline should be set as 31 January 2021.

Extension request

Positions of parties

  1. The BCBA, Connexion Matawinie, and TCI submitted that the dates established in the notice do not provide sufficient amount of time to prepare a full intervention that properly addresses the four broad issues identified by the Commission and the questions posed, and noted that the proceeding comes in the midst of a number of filing deadlines for other Commission proceedings regarding telecommunications policy. These include the proceedings initiated by Telecom Notice of Consultation 2020-131, Telecom Notice of Consultation 2020-187, Telecom Notice of Consultation 2019-406, and, most recently, Telecom Notice of Consultation 2020-367.
  2. Videotron supported TCI’s request to extend the period for submission of interventions until 18 December 2020, but opposed BCBA’s request for an extension until 18 January 2021, arguing that BCBA has not put forward any arguments that could justify such an extension, given the urgency of the situation. The FCM agreed with Videotron’s views.

Commission’s analysis and determinations

  1. The Commission considers that the request by TCI to extend the deadline for filing initial interventions by 18 days, and to revise all subsequent procedural dates accordingly, such that the deadlines of other large proceedings do not overlap with those of this proceeding, is reasonable under the circumstances.
  2. In order to strike a balance between procedural efficiency and the need for more time, especially for smaller players, and in view of the importance of the matter being addressed in this proceeding, the Commission is extending the deadline for initial interventions to 18 December 2020. The Commission is also revising all subsequent procedural dates accordingly.


  1. In light of the above, the Commission amends the procedural dates set out in paragraphs 29, 31, 34, 35, and 36 of the notice. For ease of reference, the relevant paragraphs are reproduced below, with changes highlighted in bold italics:

    29. All ILECs and SILECs that have a support structure services tariff are made parties to this proceeding and may file interventions with the Commission by 18 December 2020.

    31. Interested persons who wish to become parties to this proceeding must file an intervention with the Commission regarding the above-noted issues by 18 December 2020. The intervention must be filed in accordance with section 26 of the Rules of Procedure.Footnote 1

    34. All parties may file replies to interventions with the Commission by 19 January 2021.

    35. Parties to this proceeding will have the opportunity to propose requests for information to further the Commission’s understanding of the relevant issues. These proposals, the requests for information, and the responses that are ultimately filed will form part of the record of this proceeding. Therefore, parties that wish to request information from other parties may file their proposed questions with the Commission by 3 February 2021. These proposed questions will be taken into account in the formulation of requests for information.

    36. Further processes will be announced via procedural letters and/or updates to this notice at future dates. Those processes will include the dates by which parties are to file final submissions and final replies, if needed.

Secretary General

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