Telecom - Procedural Letter adressed to the Distribution List
Ottawa, 24 September 2021
Our reference: 8740-S22-202104610, 8740-B38-202104628, 8740-B38-202104686, 8740-R28-202104636, 8740-T66-202104876, 8740-T66-202104884
RE: Bell Mobility Inc. request to extend the filing deadline for replies to its wholesale MVNO and wholesale roaming tariffs
Dear Madam, Sir:
On 14 September 2021, Commission staff issued a letter granting a 10 day extension to the deadline for filing reply comments for the above-referenced tariff notices filed by Bell Mobility Inc. (Bell Mobility), Rogers Communications Canada Inc. (RCCI), Saskatchewan Telecommunications (SaskTel), and TELUS Communications Inc. (TELUS).
On 21 September 2021, Bell Mobility filed a letter requesting a Commission decision to grant the 20 day extension request, as originally proposed by RCCI. The Commission received comments from Quebecor Media inc. (Videotron) and RCCI.
Bell Mobility submitted that it and the other tariff applicants were in receipt of a total of 10 interventions, several of which are 50 or more pages in length, and in some cases include new proposals that are more akin to new tariff proposals than they are comments on its proposed tariffs. It argued that the principles of natural justice and procedural fairness require that the tariff applicants be given sufficient time to fully review and respond to these detailed and lengthy interventions.
Bell Mobility also indicated that two of its subject matter experts were unavailable during the 10 day reply period due to scheduling conflicts and asked for procedural flexibility in this regard, as has been done in the past.
RCCI supported Bell Mobility’s request.
Videotron indicated that it would not oppose Bell Mobility’s request because doing so could risk further delays. However, Videotron urged the Commission to take note of the fact that even at this early stage of the process, the national carriers are already attempting to delay the implementation of wholesale MVNO access.
In the Commission’s view, the comments filed by interveners are substantial and cover a significant number of policy and technical issues. Several interveners have proposed extensive and specific modifications to numerous provisions included in the proposed tariffs, in addition to the many general policy issues that have been raised.
Given the complexity of the interventions, the Commission considers that granting an additional 10 days to the tariff applicants would be reasonable in order to build a fulsome record. The Commission does not consider that such an extension would materially impact the timelines associated with its consideration of the associated tariff notices.
For these reasons, the Commission approves of the request for a further 10 day extension for Bell Mobility, RCCI, SaskTel and TELUS to file their reply comments. The new filing date is 7 October 2021.
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