Telecom Commission Letter addressed to Dennis Béland (Québecor Média) and Robert Malcolmson (Bell Canada)
Ottawa, 24 April 2020
Our reference: 8660-V3-201904516
Vice-President, Regulatory Affairs
612 St-Jacques Street, 15th Floor
Montreal, QC H3C 4M8
Chief Regulatory Officer
160 Elgin Street, 19th Floor
Ottawa, ON K2P 2C4
RE: Follow-up to Telecom Decision CRTC 2020-48, Videotron Ltd. (Videotron) – Application for final relief requesting that the Commission order Bell Canada, on behalf of Bell Mobility Inc., to abstain from suspending wholesale roaming services offered to Videotron (Telecom Decision 2020-48) – Request to suspend the submission of reports
On 5 February 2020, the Commission published Telecom Decision 2020-48 approving an application for final relief ordering Bell Canada, on behalf of Bell Mobility Inc. (collectively, Bell), to abstain from suspending wholesale roaming services offered to Videotron. In subparagraph 58(iv) of this decision, the Commission ordered Videotron, over a six-month period beginning on 15 April 2020, to set out in a report for Bell and the Commission a list of the IMSIs Footnote1 of the end-users to whom Videotron issued two-month and three-month permanent roaming notifications. Footnote2
In a letter to the Commission dated 8 April 2020, Videotron stated the following:
- In light of the COVID-19 crisis, a number of telecommunications service providers, including Videotron, have taken various measures to minimize as much as possible any adverse impacts.
- Videotron is making every possible effort to ensure service continuity for the essential services that are telecommunications and media and to support its customers and employees. To this end, Videotron has implemented a series of time-limited measures to make customers’ lives easier.
- In addition to the above, Videotron has temporarily halted the enforcement of certain safeguards against permanent roaming. Given the unprecedented situation and the unexpected effect it has had on customers’ usage of wireless services, as well as how harmful it would be for these customers to lose access to roaming services at this time, Videotron finds that it would be unreasonable to continue sending suspension notifications to customers having exceeded the normal roaming thresholds.
Videotron stated that there is no utility in sending Bell and the Commission blank monthly reports. In the current context, and to ensure it can meet its obligations, Videotron requested that the Commission suspend for three months the order set out in subparagraph 58(iv) of Telecom Decision 2020-48. If this request is approved, Videotron’s first monthly report would cover the period of 15 July to 14 August 2020, and would be sent to Bell and to the Commission shortly after this period ends.
In a letter to the Commission dated 14 April 2020, Bell responded that it does not object to Videotron’s request to suspend the order to produce monthly reports. However, Bell stated that if Videotron wishes to be exempted from the conditions of Bell’s wholesale roaming tariff, set out in accordance with section 25 of the Telecommunications Act (the Act), Videotron should obtain prior approval for such an exemption from the Commission. Bell stated that it would not be opposed to the temporary suspension of safeguards against permanent roaming if Videotron were to make such a request.
In a letter to the Commission dated 16 April 2020, Videotron stated that Bell’s contention is unfounded because it has a series of other safeguards against permanent roaming in place and Commission policy holds that some legitimate permanent roaming should be permitted as a consumer- and competition-friendly practice. In Videotron’s view, temporarily allowing a very small number of Canadians to focus on their family and professional obligations during an unprecedented pandemic, without worrying about the service suspension notices they may have otherwise received, is most definitely a “valid reason” as set out in Commission policy. Footnote3
Commission’s analysis and determinations
Given the extraordinary circumstances and Bell’s lack of objections, the Commission deems reasonable Videotron’s request to suspend for three months its obligation to submit monthly reports as required by Telecom Decision 2020-48.
Bell indicated that it would not object to the temporary suspension of safeguards against permanent roaming if Videotron requested as much. That being said, Videotron has stated that it maintains a series of other operational safeguards.
The Commission notes that the policy established in Telecom Decision 2017-56 allows for some legitimate permanent roaming under certain circumstances and deems it to be a consumer- and competition-friendly practice. The Commission therefore does not currently find it necessary to require Videotron to seek approval to temporarily suspend its obligation to meet the conditions of Bell’s wholesale roaming tariff.
Consequently, the Commission approves Videotron’s request to suspend for three months the order set out in subparagraph 58(iv) of Decision 2020-48. The first monthly report submitted will cover the period from 15 July to 14 August 2020 and will be sent to Bell and to the Commission shortly after this period ends.
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