Procedural Letter adressed to the Distribution List
Ottawa, 14 September 2021
Our reference: 8740-S22-202104610, 8740-B38-202104628, 8740-B38-202104686, 8740-R28-202104636, 8740-T66-202104876, 8740-T66-202104884
RE: Request to extend the reply period for various Tariff Notices associated with mandated MVNO access services
Commission staff is in receipt of an 8 September 2021 letter from Rogers Communications Canada Inc. (RCCI) requesting that the Commission extend the reply deadline for interventions filed on 7 September 2021 in response to applications under Tariff notice 0372, 0005, 0006, 0072, 0563, and 0564, filed respectively by Bell Mobility Inc. (Bell Mobility), Rogers Communications Canada Inc. (RCCI), Saskatchewan Telecommunications (SaskTel), and TELUS Communications Inc. (TCI).
RCCI submitted that given that the interventions filed were numerous, substantial, and complex, that it would require additional time to provide meaningful replies. Further, RCCI noted that it is of critical importance to ensure that the Commission’s determinations in TRP 2021-130 are realized without negatively impacting investment. As result, RCCI requested that the Commission extend the reply deadline 20 days from 17 September 2021 to 7 October 2021, noting that the Commission granted interveners a similar extension.
On 9 and 10 September 2021 Bell Mobility, Quebecor Media Inc., on behalf of Videotron Ltd. (Videotron), RCCI, SaskTel and Xplornet Communications Inc. and Xplore Mobile Inc., (together, “Xplornet”) filed a reply to RCCI’s request.
Videotron and Xplornet opposed the length of the extension request. Videotron argued that the extension requested was too long given the urgency to have the tariffs in place, and that the requested extension was not proportional to the extension granted to intervenors. Instead, Videotron proposed an extension of 10 days. Xplornet agreed with Videotron’s proposal, submitting that this would provide the time required to meaningfully respond to comments, while avoiding the introduction of unnecessary delay.
Bell Mobility, SaskTel and TCI supported RCCI’s request. Bell Mobility submitted that the requested extension was not unreasonably long given the complexity of the file, and would still be considerably less than the 50-55 days intervenors were given to prepare their interventions. Further, that the delay would not prejudice the MVNO service because the seven-year period during which the tariff will be in force will not commence until the tariffs are approved. TCI argued that without the ability to respond fully to other parties, the Commission risks mandating terms and conditions for the services that do not reflect its policy determinations or are infeasible from a technical perspective.
Staff considers that given the complexity of the interventions filed, each with substantive comments on the proposed tariffs, that the request to extend the deadlines for reply comments is reasonable. However, staff considers that it is sufficient to extend the reply comments deadlines until 27 September 2021, which would provide parties with a total of 20 calendar days for filing reply comments.
Original signed by
Director, Telecommunications Services Policy
c.c.: Jeremy Lendvay, CRTC, Jeremy.Lendvay@crtc.gc.ca
Ethan Townsend, CRTC, Ethan.Townsend@crtc.gc.ca
Attach (1) Distribution List
Bell Canada, Bell Mobility email@example.com;
Cogeco Leonard.Eichel@cogeco.com; firstname.lastname@example.org;
Iristel email@example.com; firstname.lastname@example.org; email@example.com;
Manitoba Coalition firstname.lastname@example.org; email@example.com;
RCCI firstname.lastname@example.org; Regulatory@rci.rogers.com;
TerreStar Solutions email@example.com;
TCI Jessica.Robb@telus.com; firstname.lastname@example.org;
Vaxination Informatique email@example.com;
Videotron firstname.lastname@example.org; email@example.com;
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