Telecom - Commission Letter addressed to the Distribution List

Ottawa, 25 February 2022

Our reference: 8740-S22-2021046108740-B38-2021046288740-B38-2021046868740-R28-2021046368740-T66-2021048768740-T66-202104884


Distribution List

RE:  Procedural requests for i) the filing of template agreements,  ii) the addition of a final comment phase in relation to tariff notices for wholesale MVNO access and wholesale roaming services, and iii) disclosure and further responses to requests for information (RFIs)

This Commission staff letter addresses three procedural matters related to the tariff notice proceedings (see file numbers above) for wholesale MVNO access and wholesale roaming services (the tariff proceedings), pursuant to the Commission’s determinations in Telecom Regulatory Policy 2021-130, Review of mobile wireless services (TRP 2021-130). First, a request made by Iristel Inc. (Iristel) on behalf of itself and its affiliate Ice Wireless Inc. related to template agreements. Second, a request by Vaxination Informatique (Vaxination) to add a reply phase to the tariff proceedings. Third, requests made by Iristel and Cogeco Connexion Inc. (Cogeco) for disclosure and further responses to RFIs.

Iristel’s procedural request came in a letter dated 9 August 2021 where it requested that the Commission direct Bell Mobility Inc., Rogers Communications Canada Inc., TELUS Communications Inc. (collectively, the national wireless carriers) and Saskatchewan Telecommunications (SaskTel) to place their template agreements for wholesale MVNO access and seamless roaming services on the record of the tariff proceedings for comment by interested parties.

Iristel submitted that interveners should be provided an opportunity to assess whether those agreements contain any anti-competitive provisions or undermine the objectives set out in TRP 2021-130.

The national wireless carriers and SaskTel submitted that the Commission should deny the request. They submitted that the request is inconsistent with the procedure established by the Commission, is out of process, would introduce unnecessary complexity, would cause delay, and is unnecessary. In addition, they generally submitted that they have not yet prepared any such agreements, nor have they updated their wholesale roaming agreements since those agreements would depend on the outcome of the tariff proceedings.

In a letter dated 21 August 2021, Commission staff indicated that Iristel’s request was under consideration. Having reviewed the record to date including the recent responses to requests for information, Commission staff is of the view that, given the number and complexity of issues that have been raised by parties concerning the proposed tariffs, there would be little probative value in requiring the tariff applicants to file template agreements with the Commission until the tariff proceedings are complete and the tariffs have been finalized. As such, Iristel’s request is denied. While any future agreements would be expected to align with the tariffs eventually approved by the Commission, template agreements may be requested for filling purposes following the conclusion of the tariff proceedings.

Vaxination’s procedural request came in a letter dated 28 January 2021, where it sought confirmation as to whether parties would be provided an opportunity to reply to responses to RFIs. TELUS supported the addition of a response phase. No other party commented on this request. In Commission staff’s view, adding a final comment or reply phase is unnecessary, as it would not materially add to the extensive public record that has already been developed through interventions, replies, and responses to RFIs. As a result, Vaxination’s request is also denied.
Finally, with respect to Cogeco and Iristel’s requests for further responses to RFIs from Bell Mobility and TELUS (in letters dated 7 February 2022 respectively), Commission staff notes that neither Cogeco nor Iristel posed the original RFIs and therefore do not qualify as requesting parties under s.75 of the Canadian Radio-television and Telecommunications Commission’s Rules of Practice and Procedure. In any event, Commission staff is of the view that no further responses are required.

With respect to Iristel’s request for disclosure of information submitted in confidence by Bell Mobility, Commission staff notes that Bell Mobility has since disclosed the information of its own volition.

In light of the above, and with a view towards minimizing further procedural delays in the tariff proceedings, Commission staff considers that the records of the tariff proceedings are closed. 


Original signed by


Philippe Kent
Director, Telecommunications Services Policy
Telecommunications Sector

c.c.:     Jeremy Lendvay,
Ethan Townsend,
Julian Brainerd,  


Attachment: Distribution List



Distribution List



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