Telecom - Staff Letter addressed to the Distribution List
Ottawa, 16 June 2023
Our reference: 1011-NOC2023-0056
BY EMAIL
Distribution List
Subject: Telecom Notice of Consultation 2023-56 – Denial of Bell Canada’s Request for an Extension to Tariff Filing and Cost Study Deadlines
On 8 March 2023, the Canadian Radio-television and Telecommunications Commission (Commission) published Telecom Notice of Consultation 2023-56 (the Notice). The Notice commences a review of the wholesale high-speed access service (HSA) framework.
The Notice directs incumbent carriers to file new Phase II cost studies to establish rates for aggregated wholesale HSA services by 22 June 2023.
On 9 June 2023, Bell Canada (Bell) requested an extension of that filing deadline from 22 June 2023 to
15 August 2023.
Owing to a range of factors, including the strong public interest in a timely decision on this proceeding, Commission staff denies Bell’s request.
Reasons for Denial
All parties were notified via a 4 May 2023 letter that “the Commission is not predisposed to granting any further extension requests” in this proceeding. This position was informed by the strong public interest in moving expeditiously to facilitate vibrant and sustainable internet service competition. It also accords with the Government of Canada’s recent Policy DirectionFootnote1, which requires the Commission to conduct proceedings in a timely manner.
The 4 May 2023 letter sets out that deadline extensions may be granted in rare and exceptional circumstances, and where the request is supported by sufficient evidence. Commission staff acknowledges the effort that Bell dedicated to substantiating its extension request. However, even in the face of such evidence, the circumstances surrounding the extension request are neither rare nor exceptional.
Commission staff notes that no other incumbent carrier has indicated a need to extend the 22 June 2023 deadline. Specifically, the only incumbent who replied to Bell’s request—Québecor Média—indicated that it expects to be able to meet the established deadline for its own cost studies and saw no reason why Bell would not be in the same position.
Bell also asserted that it cannot meet the 22 June 2023 deadline owing to competing demands for its costing resources. This is in itself not sufficient grounds for granting an extension request. Each company is expected to ensure that it has, or puts in place, the resources necessary to respond to the Commission’s directions.
Conclusion
The strong public interest in delivering competitive and affordable internet access demands that both the Commission and the industry work hard to meet the deadlines in this proceeding. We will continue to work with all parties, in the spirit of cooperation, towards developing a framework that will serve all Canadians.
Yours 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;
CNOC, regulatory@cnoc.ca;
Community Fibre, ben@communityfibre.ca;
Comwave, legal@comwave.net;
Public Interest Advocacy Centre, jlawford@piac.ca;
TekSavvy, regulatory@teksavvy.ca;
Vaxination Informatique, jfmezei@vaxination.ca;
John Roman, johnphiliproman@gmail.com;
WaveDirect Telecommunications Limited, joanne@wavedirect.org;
Vaxxine Computer Systems Inc., president@vaxxine.com;
Truespeed Internet Services Inc., adam@truespeed.ca;
SkyChoice Communications, serge@skychoice.ca;
Securenet, info@securenet.net;
Secure by Design, kirk@secure-by-design.com;
OpenMedia, erin@openmedia.org;
Netrevolution inc., drouleau@gtvr.com;
National Capital FreeNet, execdir@ncf.ca;
IGS Hawkesbury Inc., jbogue@hawkmail.ca;
First Mile Connectivity Consortium, info@firstmile.ca;
Devtel Communications Inc., devin@devtelcommunications.ca;
CPC, campbell@campbellpatterson.com;
Canadian Anti-Monopoly Project (CAMP), keldon@antimonopoly.ca;
Beanfield , todd@beanfield.com;
Marc Nanni, mn_crtc@proton.me;
Competition Bureau, Conor.Parson@cb-bc.gc.ca;
Competition Bureau, crtc2023-56@cb-bc.gc.ca;
Coextro, skhandor@coextro.com;
Carry Telecom, frankw@carrytel.ca;
Execulink, yasmin.charania@execulinktelecom.ca;
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