Telecom - Staff Letter addressed to Howard Slawner (Rogers Communications Canada Inc.)
Ottawa, 23 June 2023
Reference(s): 8622-V3-202302040
BY E-MAIL
Howard Slawner
Rogers Communications Canada Inc.
Vice President – Telecom
1 Mount Pleasant Road
Toronto ON M4Y 2Y5 Canada
Howard.Slawner@rci.rogers.com
Subject: Final offer arbitration regarding mobile virtual network operator (MVNO) access rates – request regarding confidentiality claims
Dear Howard Slawner,
On 5 June 2023 the Commission received a submission from Rogers Communications Inc. (Rogers), in the context of final offer arbitration regarding mobile virtual network operator (MVNO) access rates (the FOA). This submission included public abridged versions of Rogers’ cover letter and final offer submission from 12 May 2023 and its cover letter and reply submission from 29 May 2023.
Staff notes that in Telecom Information Bulletin 2022-337, Footnote1 the Commission explained that it is of particular importance for the attainment of the objectives set out in Telecom Regulatory Policy 2021-130, as well as in the public interest, that all carriers that provide or access wholesale MVNO services be provided with sufficient information to understand the Commission’s rationale and decisions. As such, the Commission noted its aim to release as much information and rationale as possible to the public in its decisions on FOA proceedings on MVNO access rates.
To that effect, Commission staff has reviewed the public redacted versions of these documents. Staff has identified a list of paragraphs that, in part or in whole, do not clearly fall within one of the categories of information that can be designated confidential pursuant to section 39(1) of the Telecommunications Act, or for which disclosure would be in the public interest.
- In the 12 May 2023 submission cover letter: paragraphs 3 (second and third bullet points only), 4, 6, 8, and 11.
- In the 12 May 2023 submission: paragraphs 2, 3, 8, 16, 19, 30, 34 (excluding table), 35 through 41, 42 (excluding information provided to the Commission only), 43 (excluding table), 44 through 47, 48 (excluding monetary values and information provided to the Commission only), 49 through 52, 53 (excluding middle column of table), 54, 57 through 59, 62 through 64, 68 (second sentence only), 69 through 71, 72 (first sentence only), 76, 79 through 84, and 87.
- In the 29 May 2023 reply submission cover letter: paragraph 2.
- In the 29 May 2023 reply submission: paragraphs 2, 3 (excluding monetary values), 4, 7 (excluding monetary values), 8, 10, 12 (excluding percentage value), 13 through 17, 20 (excluding monetary value), 23 (excluding percentage values), 25 (excluding monetary value), 28 (excluding 28(b)), 31, 32 (excluding numerical and monetary values), 33, 34 (excluding numerical and monetary values), 36, 37 (first sentence only), 38, 39 (excluding details about the parties and rates), 45 (excluding monetary values).
For each of the listed paragraphs that you believe should remain confidential, in whole or in part, please provide a detailed explanation as to how the redacted information falls into one of the categories listed in s.39(1) of the Act and a detailed rationale to explain why its disclosure would not be in the public interest. In particular, please explain whether the disclosure of the information that Rogers seeks to keep confidential would be likely to result in any specific direct harm, and precisely what harm would arise. Please explain how such specific direct harm would outweigh the public interest in disclosure.
In addition, please resubmit public abridged versions of these documents so that staff can confirm any changes to the redactions.
Staff asks that a response and abridged versions of the documents be provided within 5 calendar days of receiving this Letter.
Yours sincerely,
Original signed by
Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector
c.c. Philippe Nadeau, CRTC, Philippe.nadeau@crtc.gc.ca
Leila Wright, CRTC, leila.wright@crtc.gc.ca
Marisa Wyse, Rogers, marisa.wyse@rci.rogers.com
Peggy Tabet, Québecor, tabet.peggy@quebecor.com
Joshua Bouzaglou, Québecor, joshua.bouzaglou@quebecor.com
Melanie Cardin, Québecor, Melanie.Cardin@quebecor.com
- Date modified: