Telecom - Staff Letter addressed to the Distribution List
Ottawa, 27 March 2023
Reference: 1011-NOC2023-0056
BY EMAIL
Distribution
RE: Request to extend filing deadlines for tariff filings and cost studies in Notice of hearing - Review of the wholesale high speed access framework, Telecom Notice of Consultation 2023-56
The Commission is in receipt of a letter dated 21 March 2023, submitted by Bell Canada, requesting an extension to the filing deadlines for tariff filings and cost studies set out in Notice of hearing - Review of the wholesale high speed access framework, Telecom Notice of Consultation 2023-56 (NOC 2023-56).
Bell Canada requested that the due date for submitting proposed tariffs and supporting cost studies for fibre-to-the-premises (FTTP) facilities over aggregated wholesale High Speed Access (HSA) services, and its position on whether those services should be mandated on an interim basis pending the conclusion of this proceeding, be extended from 24 April 2023 to 6 June 2023. It also requested that the due date for the filing of updated tariffs and supporting cost studies for the existing aggregated wholesale HSA services, as well as comments on the remaining issues raised in the proceeding be extended from 22 June 2023 to 8 August 2023. Bell Canada suggested that these revised due dates should apply to all other carriers that have been mandated to file similar submissions by the same dates.
Bell Canada submitted that it is not feasible for it to complete a Phase II cost study within six weeks for FTTP facilities over aggregated wholesale HSA services, and a further Phase II cost study with respect to pre-existing aggregated wholesale HSA services 8 weeks thereafter. It argued that these timeframes are significantly out of step with those the Commission imposed when it required parties to make similar filings in previous proceedings. With respect to the expedited process set out in NOC 2023-56, Bell Canada submitted that its positions on whether FTTP facilities over aggregated wholesale HSA services should be mandated on an interim basis will be informed by the cost of implementation and the proposed tariffs for the service, and as such, the due date for the filing of those positions should be extended so that it is the same as the filing date for the cost study.
The Commission is also in receipt of letters from other incumbent carriers, including Bragg Communications Inc, Cogeco Communications, Rogers Communications Canada Inc., Saskatchewan Telecommunications, Shaw Cablesystems G.P. (Shaw), and TELUS agreeing with the need to provide extensions to the filing deadlines set out in NOC 2023-56. Meanwhile, other letters have been received, such as those from Québecor Média and Teksavvy Solutions Inc. (Teksavvy), disagreeing with the need to provide any such extensions.
Commission staff notes that, in Order Issuing a Direction to the CRTC on a Renewed Approach to Telecommunications Policy, SOR/2023-23, 10 February 2023 (the Policy Direction) the Commission is directed to conduct its proceedings in a timely manner and to ensure that its framework for fixed Internet competition provides adequate options in terms of speeds and services for competitors on a timely basis. To that end, the Commission has established the filing dates set out in NOC 2023-56 with the intention of resolving key policy issues as expeditiously as possible.
Commission staff considers that, while filing dates in this proceeding are necessarily shorter than those that have been set in previous proceedings, these deadlines provide sufficient time for parties to prepare their submissions. Commission staff notes, for example, that one of the carriers subject to an obligation to provide wholesale HSA services has indicated that it believes itself capable of providing the information required within the existing deadlines. This carrier is of a smaller scale than many of the others that requested extensions and has a more limited history with FTTP facilities.
Given the above, Commission staff considers that the filing dates established in NOC 2023-56 are appropriate.
Commission staff notes that other issues beyond filing deadlines have been raised by certain parties, for example those identified by Shaw and Teksavvy. Such issues will be dealt with separately and at a later time. While these matters are being considered, parties are to proceed with existing directions.
Sincerely,
Original signed by
Leila Wright
Executive Director
Telecommunications
Distribution List
Bell Canada, bell.regulatory@bell.ca;
Cogeco, telecom.regulatory@cogeco.com;
Eastlink, regulatory.matters@corp.eastlink.ca;
RCCI, regulatory@rci.rogers.com;
SaskTel, document.control@sasktel.com;
Shaw, Regulatory@sjrb.ca;
TCI, regulatory.affairs@telus.com;
Videotron, regaffairs@quebecor.com;
Teksavvy, regulatory@teksavvy.ca
- Date modified: