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Telecom - Commission Letter addressed to the Distribution List

Ottawa, 27 September 2022

Multiple References

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Distribution List

RE: Consideration of matters raised in TELUS Communications Inc. application requesting reclassification of small incumbent local exchange carriers within the next-generation 9-1-1 ecosystem and various procedural directions relating to a number of interrelated proceedings

By letter issued on 16 September 2022, the Commission merged a number of proceedings dealing with matters pertaining to next-generation 9-1-1 (contained at Appendix 1) and established new process. The letter included various requests for information (RFIs) and provided an opportunity for parties to comment on answers given to these requests.

Subsequent to the release of that 16 September 2022 letter, the Independent Telecommunications Providers Association (ITPA) filed a procedural with the Commission, dated 19 September 2022, in which it submitted that it and its member companies would be unable to meet the 30 September 2022 deadline for answering the RFIs due to a lack of staff and internal resources, as well as being otherwise occupied with responding to other RFIs related to NG9-1-1 proposed rates and wireless and roaming agreements for wholesale.

In addition, the ITPA submitted that the Commission’s current process does not provide for an opportunity for the ITPA to reply to comments that may be filed in response to answers to the above-referenced RFIs. The ITPA asserted that procedural fairness and natural justice demanded that the ITPA and its member companies be given the right to reply to any comments filed by parties regarding the answers to the RFI filed by the ITPA and its members.

Consequently, the ITPA requested that the Commission (i) extend the deadline for filing responses to the RFIs to 14 October 2022; and (ii) introduce additional process whereby the ITPA would be permitted to file a reply to comments by parties on the RFI answers by 11 November 2022.

TELUS, via letter filed with the Commission 22 September 2022, supported for the most part the ITPA’s request but took issue with some of the proposed timelines and expressed opposition to the ITPA’s proposal that only it and its members be provided a new additional procedural step.

Commission staff acknowledges that the RFIs issued on 16 September 2022 include questions of a complex and technical nature and that the development of full and complete answers may pose a challenge to the ITPA and its member companies in their present circumstances. Given the potential impacts the answers to the RFIs may have on the outcome of the issues being considered in the merged proceeding, staff considers it appropriate to extend the deadline by which answers to the RFIs are due, as requested by the ITPA.

With regards to the request for additional process whereby the ITPA would be provided an opportunity to reply to comments made by other parties in relation to the answers to the RFIs, staff considers the existing process is consistent with procedural fairness requirements given that the issues to be determined are known and that the existing process provides ample opportunities for all interested persons to make their case. Nevertheless, staff acknowledges that the additional process suggested by the ITPA could prove beneficial to the development of a more fulsome record and considers it appropriate to establish additional process in this regard.

Notwithstanding the preceding, staff is of the view that any additional procedural steps and extensions to existing deadlines should not be solely for the benefit of the ITPA and its members. Consequently, staff accepts the ITPA’s proposal with modifications and amends the procedures as follows:

  1. The deadline by which ILECS and SILECs are to provide answers to the relevant RFIs is extended to 14 October 2022;
  2. The deadline by which the ITPA, its member companies and interested persons may respond to the matters raised in TELUS’ application is extended to 28 October 2022;Footnote1
  3. The deadline by which parties to the various proceedings being merged may file amendments to any of their submissions as a result of the merging of records is extended to 28 October 2022. Staff reminds parties that submissions in this regard are to be restricted to commenting on the impact on their existing submissions brought about by the merging of records. In doing so, parties are to file their amended comments using file number 8633-T66-202201755 but reference within their comments the file number associated with their original submissions;
  4. The deadline by which ILECs and SILECs may reply to comments made in relation to their respective answers to the RFIs is 4 November 2022; and
  5. The deadline by which TELUS may respond to any submissions made in direct response to the matters raised in its application is extended to 11 November 2022.

Sincerely,

Original signed by Étienne Robelin for

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.:  Chris Noonan, CRTC, chris.noonan@crtc.gc.ca, 873-354-0359;
Stais Armstrong, CRTC, stais.armstrong@crtc.gc.ca, 819-862-5720;
Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca, 873-354-4325;
Daniel Cardozo, CRTC, daniel.cardoza@crtc.gc.ca, 819-862-5720;
B. Natraj (Nat Natraj), CRTC, nat.natraj@crtc.gc.ca, 819-953-5081

Distribution List

Parties to the TELUS Part 1 Application
Parties to NOC 2022-65
Parties to the ITPA Part 1 Application
Parties to NG9-1-1 Tariff Applications
SILECs
ILECs

Appendix 1 – Commission References

8633-T66-202201755 – Part 1 Application from TELUS Communications Inc. requesting that SILECs be classified as Originating Network Providers for NG9-1-1;
1011-NOC2022-0065 – Notice of Consultation 2022-65 – Call for comments – Funding next-generation 9-1-1 access services through the National Contribution Fund;
8663-J92-202101369 – Part 1 Application from the Independent Telecommunications Providers Association (ITPA) regarding the development of retail and wholesale NG9-1-1 rates in the geographic areas covered by SILEC exchanges;
8740-Q29-202107466 – Tariff Notices 14, 14/A, 9315-1884 Québec Inc.
8740-B6-202107325 – Tariff Notices 22, 22/A, 22/B, Brooke Telecom Co-operative Ltd.
8740-B7-202107341 – Tariff Notices 161,161/A, 161/B, Bruce Telecom Ontario Inc. 
8740-C1-202107226 – Tariff Notices 79, 79/A, Cochrane Telecom Services
8740-C41-202107599 – Tariff Notices 88, 88/A, 88/B, CoopTel, coop de télécommunication
8740-E25-202107333 – Tariff Notices 79, 79/A, Execulink Telecom Inc.
8740-H3-202107440 – Tariff Notices 33, 33/A, Hay Communications
8740-H4-202107432 – Tariff Notices 40, 40/A, HuronTel
8740-G2-202107680 – Tariff Notices, 22, 22/A, Gosfield North Communication Co-operative Limited
8740-L3-202107482 – Tariff Notices, 18, 18/A, Lansdowne Rural Telephone Company
8740-M5-202107416 – Tariff Notices 70, 70/A. Mornington
8740-N24-202107367 – Tariff Notices 52, 52/A, Nexicom Telecommunications, a Division of Nexicom Inc.
8740-N23-202107359 – Tariff Notices, 44, 44/A, Nexicom Telephones, a Division of Nexicom Inc.
8740-N7-202107549 – Tariff Notice 35, 35/A, North Frontenac Telephone Corporation Ltd.
8740-N10-202107375 – Tariff Notices, 44, 44/A, North Renfrew Telephone Company Limited Trade
8740-Q2-202107581 – Tariff Notices 37, 37A, Quadro Communication Co-operative Inc.
8740-S4-202107458 – Tariff Notices 189, 189/A, Sogetel Inc.
8740-W3-202107383 – Tariff Notices 46, 46/A, The Westport Telephone Company, Limited
8740-T7-202107557 – Tariff Notices 34, 34/A, Tuckersmith Communications Co-operative Limited
8740-W4-202107474 – Tariff Notices 33, 33/A, Wightman Telecom Ltd.
8740-T8-202107531 – Tariff Notices 174, 174/A, Tbaytel
8740-T66-202107490 – Tariff Notice 565, TELUS Communications Inc.
8740-B20-202107094 – Tariff Notices 968, 968A, Bell Canada
8740-S22-202107515 – Tariff Notices 373, 373A, Saskatchewan Telecommunications

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