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Telecom - Commission letter adressed to the Philippe Gauvin (Bell Canada)

Ottawa, 23 September 2021

Our reference:  8740-B2-202105775, 8740-A53-202105824, 8740-M59-202105783, 8740-N1-202105858, 8740-T78-202105832, 8740-M22-202105809, 8740-K1-202105791, 8740-N51-202105816, 8740-D3-202105840

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19
100 Elgin St.
Ottawa, ON K2P 2C4
bell.regulatory@bell.ca

RE:  Bell Canada Tariff Notice 7634, Bell Aliant Tariff Notices 552, 552A, Bell MTS Tariff Notices 837, 837A, Northwestel Tariff Notice 1139, Télébec Tariff Notice 521, Maskatel Tariff Notice 86, KMTS Tariff Notice 95, NorthernTel Tariff Notice 408, DMTS Tariff Notice 83 – Connection to in-building Wire

Dear Philippe Gauvin:

On 27 August 2021, the Commission received an application from Bell Canada under tariff notice (TN) 7634, proposing revisions to the company’s Access Services Tariff CRTC 7516, Item 105 – Local Network Interconnection and Component Unbundling, in order to update the tariff pursuant to Access to in-building wire in multi-dwelling units, Telecom Regulatory Policy CRTC 2021-239, 27 July 2021 (TRP 2021-239).

Concurrently with TN 7634, Bell Canada also filed the following tariff notices under separate cover:

  1. Bell Aliant, a division of Bell Canada, TN 552 and 552A to amend CRTC 21491 – Item 646;
  2. Bell MTS Inc., a division of Bell Canada, TN 837 and 837A to amend CRTC 24006 – Item 105;
  3. Télébec, société en commandite, TN 521 to amend CRTC 25140,  Item 7.8.3;
  4. Groupe Maskatel LP, TN 86 to amend CRTC 25130, Item 5.1.3,
  5. NorthernTel, Limited Partnership, TN 408 to amend CRTC 25510, Section N200, Item 15.3.08;
  6. KMTS, TN 95, to amend CRTC 25440, Section 910.3.06;
  7. DMTS, a division of Bell Canada, TN 83 to amend CRTC 25370, Section 940.3.06; and
  8. Northwestel, TN 1139, to amend CRTC 21481, Item 100, Local Network Interconnection and Component Unbundling.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed.

Bell Canada is requested by Commission staff to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 4 October 2021.

On receipt of Bell Canada’s response, interested parties may file comments by 14 October 2021 in relation to only the new information provided in response to this request for information, and Bell Canada may file reply comments by 20 October 2021.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the relevant information qualifies for designation as confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date. The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover page” located on this web page. 

A copy of this letter and all subsequent replies will be added to the public record of this proceeding.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector
c.c: Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca
Lori McLean, Eastlink, lori.maclean@corp.eastlink.ca
Carol Ho, Telus, carol.ho@telus.com

Attach. (1)

Request for Information

In TRP 2021-239, the Commission issued a number of determinations regarding access to in-building wire (IBW) in multi-dwelling units (MDUs). Among other things, the Commission directed all local exchange carriers (LECs) that have responsibility for, and control of, copper IBW in an MDU to file proposed amended or new tariff pages, within 30 days of the date of that decision, in order to provide all carrier Internet service providers (ISPs) that provide their facilities to the MDU with access to copper IBW in MDUs, on the same basis as registered LECs.Footnote1

Commission staff notes that the wording proposed by the various companies in their tariffs does not accurately reflect the wording in TRP 2021-239. Several tariffs indicate that the companies will permit the “CLEC or carrier ISP” to connect to and use the company’s copper in building wire at no charge, as opposed to the “LEC or carrier ISP.”

  1. Explain, with supporting rationale, why the company has chosen to use wording that is inconsistent with the directive in TRP 2021-239.
  2. Explain why it would not be appropriate to modify the companies’ current wording of “CLEC and carrier ISP” to “LEC and carrier ISP”, which would more accurately reflect the wording of TRP 2021-239. If the wording of TRP 2021-239 would otherwise be appropriate, submit revised tariff pages for each company reflecting that wording. 
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