Telecom - Procedural Letter addressed to the Distribution List

Ottawa, 30 May 2022

Our reference: 8633-T66-202201755

Suzanne Lamarre
Therrien Couture Joli-Coeur L.L.P.

Stephen Schmidt
Vice President – Telecom Policy & Chief Regulatory Legal Counsel
TELUS Communications Inc.

RE:  TELUS Part 1 Application for reclassification of SILECs as ONPs for the purposes of NG9-1-1

Dear Suzanne Lamarre and Stephen Schmidt,

On 21 April 2022, TELUS Communications Inc. (TELUS) filed a Part 1 application (the application) in which it submitted that the Commission erred in classifying small local incumbent exchange carriers (SILECs) as next-generation 9-1-1 (NG9-1-1) providers within Telecom Regulatory Policy 2017-182 (TRP 2017-182)Footnote1 and requested that SILECs be re-classified as originating network providers for the purpose of NG9-1-1 implementation.

On 24 May 22, Therrien Couture Joli-Coeur, L.L.P (Groupe TCJ) filed a procedural request on behalf of its client the Independent Telecommunications Providers Association (ITPA) asking that the Commission summarily reject TELUS’ application by reason of procedural irregularity.  More specifically, Groupe TCJ argued that TELUS’ application is properly characterized as one to review and vary certain determinations made in TRP 2017-182. Groupe TCJ submitted that TELUS’ application was filed some 5 years after TRP 2017-182 was issued, which is far beyond the time period of 90 days for review and vary applications set out in the CRTC Rules of Practice and ProcedureFootnote2and that it would not be appropriate, given the circumstances, for the Commission to exercise its discretion to nonetheless consider the application on its merits.

Consequently, Groupe TCJ requested that the Commission i) reject without any further consideration TELUS’ Part 1 application, and ii) suspend any and all inquiry processes in this matter by the Commission and its staff until it reaches its determination.

In order to effectively consider Groupe TCJ’s request, Commission staff is of the view that it is appropriate to afford TELUS, as the applicant, an opportunity to respond to Groupe TCJ’s request. As such, TELUS may file an answer with the Commission by no later than 6 June 2022, serving a copy upon the ITPA and its legal counsel.

The ITPA may file a reply with the Commission by no later than 13 June 2022, serving a copy upon TELUS.

In light of the foregoing, all outstanding procedural deadlines associated with TELUS’ application are hereby suspended until further notice. Interested persons are therefore encouraged to regularly monitor the record of this proceeding, available on the Commission’s website at


Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementations
Telecommunications Sector

c.c.:   Étienne Robelin, CRTC,
Independent Telecommunications Providers Association
Parties to the TELUS Part 1 application

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