Telecom - Commission Letter addressed to Distribution list

Ottawa, 29 August 2022

Our reference: 8740-B38-202104628, 8740-R28-202104636, 8740-T66-202104884


Distribution list

Subject: Amended tariff notices for wholesale roaming service – requests for information

On 14 July 2021, the Commission received tariff applications from the national wireless carriers, Bell Mobility Inc. (Bell Mobility) Tariff Notice (TN) 5, Rogers Communications Canada Inc. (Rogers) TN 72 and TELUS Communications Inc. (TCI) TN 564 in which they proposed changes to their wholesale roaming tariffs to introduce seamless handoff in the wholesale roaming service (seamless roaming) pursuant to Telecom Regulatory Policy 2021-130.Footnote1

On 6 April 2022, in Telecom Decision 2022-102,Footnote2 the Commission issued a number of determinations related to the implementation of seamless roaming and directed the national wireless carriers to make changes to the proposed terms and conditions in their wholesale roaming service tariffs to enable seamless roaming.

On 21 April 2022, the Commission received applications from Bell Mobility, Rogers and TCI proposing amendments to the tariff applications to reflect the Commission’s determinations in Telecom Decision 2022-102. On 26 April 2022, Rogers proposed another amendment to its tariff application to correct an omission.

Five interveners provided comments on the amended tariff notices.

On 3 June 2022, Bell Mobility, Rogers and TCI replied to those comments. Bell Mobility also proposed another amendment to its tariff application.

Commission staff considers that additional information is required from the parties in order to obtain a full and complete record.

As such, parties are requested to provide comprehensive answers, including rationale and any supporting information, to the attached requests for information by 6 September 2022.

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.

Response or other documents must 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 webpage.

A copy of this letter and all related correspondence will be added to the public record of the tariff proceedings.

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 designated information is 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.


Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:   Julie Boisvert, CRTC, 819-953-2421,
Yael Wexler, CRTC, 819-665-8675,

Attach (1)

Distribution list

Bell Mobility Inc.,;
Braggs Communications Inc., carrying on business as Eastlink,;
Cogeco Communications Inc., on behalf of Cogeco Connexion Inc.,;
Iristel Inc., on behalf of itself and its affiliates Ice Wireless Inc. and i-MobileCA Inc.,;
Quebecor Media, on behalf of Videotron,;
Rogers Communications Canada Inc.,;
Tacit Law Regulatory,;
TELUS Communications Inc.,;
Xplornet Communications Inc. and Xplore Mobile Inc.,

Requests for information

Questions Bell Mobility, Rogers and TCI

  1. At paragraph 69 of Telecom Decision 2022-102, the Commission stated that parties are to work in good faith to have the seamless roaming service operational for a requesting regional wireless carrier within 90 days of receiving a request. The amended tariffs do not identify how the 90-day timeline will be achieved once a regional wireless carrier makes a request for seamless roaming. Explain how the company intends to achieve this timeline in view of the proposed implementation processes.
  2. Provide a list of key steps and requirements to be undertaken, and a corresponding timeline, when a regional wireless carrier wants to update cell site information.
  3. At paragraph 404 of Telecom Regulatory Policy 2021-130, the Commission noted that although the national wireless carriers argued that technical difficulties make implementation of seamless roaming impractical, they had agreed that it is possible. Accordingly, the Commission considered that workable seamless roaming standards exist today for the implementation of the service.

At paragraph 31 of Telecom Decision 2022-102, the Commission determined that providing seamless roaming as part of the wholesale roaming service is not optional and that no discretion was granted to decide whether or not to fulfill the obligation to provide seamless roaming. The Commission added at paragraph 32 that to the extent there are technical impediments, the national wireless carrier and regional wireless carrier should work together in good faith to overcome them.

In their proposed tariffs, the national wireless carriers have included language that could be interpreted as allowing themselves a certain level of discretion to deny providing seamless roaming, for example see Bell Mobility’s item 18(a)(1)dFootnote3; Rogers’ items 4.4.2, 4.5.1 and 4.5.2Footnote4; and TCI’s item 233.7Footnote5.
Explain, with supporting rationale, how the tariffs proposed by the company conform with the foregoing Commission determinations.

Questions to Rogers

  1. Explain, with supporting rationale, why the regional wireless carrier has to undertake the process described and agreed upon in the Seamless Roaming Potential Implementation Review every time it wants to provide network border information and how this process conforms with Commission’s determinations regarding seamless roaming.
  2. In its item 4.4.3, Rogers wrote that ‘Any changes to the Wholesale Roaming Customer’s underlying wireless technology and/or its wireless technology vendor should be disclosed to Rogers six months prior to the change.’ (Emphasis added)
    1. Provide the company’s views on whether its tariff should provide the regional wireless carriers a more specific definition of which kind of changes should be disclosed (e.g. any technological changes or material changes).
    2. If the company considers such clarification is necessary, identify the types of changes which would require six months prior notification.

Questions to TCI

  1. Explain why the regional wireless carrier has to undertake the process outlined in the sections 233.3(a) through (d) every time it wants to provide network border information and how this conforms with the Commission’s determinations regarding seamless roaming.
  2. In its definition of “Seamless Roaming Service” at item 233.2, TCI states that the Seamless Roaming Service is not offered as between (i) the VPMN and (ii) the network of the reseller or MVNO customers of the Wholesale Roaming Customer, nor is it offered as between (i) the VPMN and (ii) other roaming, reseller or MVNO partners of the Wholesale Roaming Customer. Explain, with supporting rationale, why resellers and MVNO customers should not be provided with the same functionality as the regional wireless carrier.
  3. In Telecom Decision 2022-102, the Commission stated that seamless roaming was not necessary for the Internet of Things (IoT) and machine-to-machine (M2M) applications on 2G and 3G networks. Explain, with supporting rationale, why TCI, at item 233.2, indicated that GSM-based Roaming Service cannot be used to enable IoT or M2M communications.
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