Telecom - Commission Letter addressed to the Distribution list

Ottawa, 19 August 2021

Our reference: 1011-NOC2020-0187


Distribution list

RE: Telecom Notice of Consultation CRTC 2020-187 (NoC 2020-187) - Call for comments – Appropriate network configuration for disaggregated wholesale high-speed access services – Request for extension to deadlines

Dear Madams/Sirs:

The Commission is in receipt of a letter from the Competitive Network Operators of Canada (CNOC), dated 13 August 2021, requesting an extension of deadlines for the next comment and reply stages of NoC 2020-187.

On 12 August 2021, the Commission issued Telecom Decision 2021-280 Footnote1 , which directed Bell Aliant, a division of Bell Canada; Bell Canada; Bell MTS Inc.; Bragg Communications Incorporated, carrying on business as Eastlink; Cogeco Communications Inc.; Quebecor Media Inc., on behalf of Videotron Ltd.; Rogers Communications Canada Inc.; Saskatchewan Telecommunications; Shaw Cablesystems G.P.; and TELUS Communications Inc. (collectively, the wholesale service providers) to make available certain information upon request and under agreed-upon non-disclosure provisions by 1 September 2021. The Commission also directed Cogeco to disclose certain responses to questions in the Appendix to NoC 2020-187 on the public record.

Also on 12 August 2021, Commission staff issued a separate letter (Staff Letter) which addressed requests for disclosure of information and deficiencies in submissions made in response to the requests for information, dated 21 April 2021. In this letter, Commissions staff directed the wholesale service providers to provide certain information by 1 September 2021. Commission staff further established deadlines for comments with respect to this additional information to be submitted by 7 September 2021 and replies to be submitted by 14 September 2021.

CNOC submitted that the Staff Letter directing the wholesale service providers to provide their disclosure and further responses by 1 September 2021, and for parties to submit their comments by 7 September 2021, leaves only 5 business days for parties to prepare and submit comments. CNOC outlined a number of reasons for its request for extension. CNOC submitted that it requires time to conduct an in depth evaluation of the business case for disaggregated wholesale HSA deployments based on the newly proposed service configurations.

CNOC submitted it will take a considerable amount of time to discern the addressable market data on a per Point of Interconnection (POI) basis using an overlay of POI location information with census data.

CNOC further submitted that prior to preparing and submitting its written submissions, it will need to update and test various other parameters of its business case analysis and share the results with its membership to ensure validity of outcomes.

Accordingly, CNOC submitted that the earliest possible deadline that will allow it to complete its analysis and provide comments is 6 October 2021. CNOC submitted that this revised deadline strikes the ideal balance between expediting procedural steps while also ensuring that parties have a meaningful opportunity to contribute to a factual record.

CNOC further submitted that a period of 7 days to file replies will be insufficient. CNOC noted that the previous comment and reply stages in NoC 2020-187 have resulted in a significant volume of submissions. CNOC further noted that there is a high probability that comments will require it to engage in further business case analyses and research. Therefore, CNOC requested 27 October 2021 as the deadline for replies.

The Commission did not receive any comments with respect to CNOC’s extension request.

In the circumstances, in order to ensure a complete and robust record, as well as to afford all parties sufficient time to make submissions regarding the additional information to be provided, Commission staff is of the view that an extension of the filing dates for comments and replies is necessary. However, Commission staff is concerned about the length of CNOC’s proposed extension request and the need for the timely completion of the record of this proceeding. Consequently, Commission staff is of the view that shorter extensions for comments and replies are appropriate.

Accordingly, the amended process and associated dates are as follows:

All documents to be filed must be received, not merely sent, by the date provided. Parties are asked to serve all other parties with any documents filed in this proceeding, and to send an electronic copy directly to Commission staff.


Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunication sector

c.c.:  Abderrahman El Fatihi, CRTC,
Tom Vilmansen, CRTC 819-997-9253

Distribution List;;;;;;;;;;;;;;;;;;;;;;;;

Date modified: