Telecom - Staff Letter addressed to the Distribution List
Ottawa, 3 August 2023
Reference(s): 1011-NOC2023-0056
BY EMAIL
Distribution List
RE: Notice of hearing - Review of the wholesale high speed access framework, Telecom Notice of Consultation 2023-56 – Requests for information
This letter addresses deficiencies and clarifications with respect to Appendix 2 of the requests for information (RFIs) issued by Commission staff on 8 March 2023, as part of the proceeding initiated by Telecom Notice of Consultation 2023-56.
Commission staff has reviewed the RFI responses and is of the view that some of the responses are deficient as there were instances where parties provided incomplete or partial responses.
The parties named in Attachment 1 are to file complete answers to the relevant RFIs by 24 August 2023. If a party is unable to provide the required information for any questions identified in the attachment, it is to provide a detailed justification as to why it is not possible for it to do so.
Pursuant to paragraph 39(4)(b) of the Telecommunications Act and the request of the Commissioner of Competition (the “Commissioner”) dated 4 May 2023, the responses, including all information designated as confidential, are also to be provided to the Commissioner at the time that they are filed with the Commission.
Parties, if they have not done so already, are also to by 10 August 2023 provide to the Commissioner of Competition their further responses and clarifications to Appendix 1 of the 8 March 2023 RFIs, including all information designated as confidential, that were previously filed with the Commission in response to the staff letter dated 13 June 2023. Parties are to acknowledge having done so in their filings pursuant to this letter.
Sincerely,
Original signed by
Philippe Kent
Director, Telecommunications Services Policy
Telecommunications Sector
c. c.: Peter Keriakos, CRTC, peter.keriakos@crtc.gc.ca
Greg Lang, CRTC, greg.lang@crtc.gc.ca
Adam Mills, CRTC, admin.mills@crtc.gc.ca
Chris Roy, CRTC, christopher.roy@crtc.gc.ca
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;
Frontier Networks, cgooey@frontiernetworks.ca;
Citywide, david@yourcitywide.com;
CIK Telecom, jordan.d@ciktel.com;
British Columbia Broadband Association (BCBA), regulatory@bcba.ca
Attachment (1)
FURTHER RESPONSES TO INTERROGATORIES
Parties identified below are to provide the information requested.
(CRTC)08Mar23-1-1b
Bell
- Provide the data by CMA where possible and, where it is not possible, use the templates included in the 8 March 2023 staff letter to provide data at an appropriate lower level of aggregation that your company tracks (e.g. by postal code, central office, etc.). Provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level. Use the “Other” field in the templates. including a supplemental document if necessary, to indicate the level of aggregation used in providing the data, which should include all relevant assumptions, calculations, and details of the data sets used in the development of the table.
- Provide the data by province where the templates requested such a level of aggregation.
- Where the data cannot be provided in the specific manner requested by the templates, Bell is to provide its best approximation. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
- Provide the ARPU for retail wireline Internet access services at the most granular level of detail available. Include ARPU data for 2018 through 2021, along with a detailed explanation of the limitations caused by the flaws in the methodology used to track prior years’ data noted in its initial reply.
- Include forecasts at the most granularity level of detail available and clearly explain any limitations or assumptions with the data provided.
- Provide a response to question 1 (c). Clearly indicate which retail internet service plans offered by Bell and its affiliates include data caps and what those data caps are.
Cogeco
- Provide the data by CMA where possible and, where it is not possible, use the templates included in the 8 March 2023 staff letter to provide data at an appropriate lower level of aggregation that your company tracks (e.g. by postal code, central office, etc.). Provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level. Use the “Other” field in the templates. including a supplemental document if necessary, to indicate the level of aggregation used in providing the data, which should include all relevant assumptions, calculations, and details of the data sets used in the development of the table.
- Where the data cannot be provided in the specific manner requested by the templates, Cogeco is to provide its best approximation. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
Rogers
- Rogers stated that it did not provide data prior to 2020 because of its inability to differentiate between HFC and FTTP. Rogers is to provide the 2018 and 2019 data at the most granular level of detail by technology available and clearly explain any limitations or assumptions with the data provided.
Videotron
- Provide a response to question 1 (c). Clearly indicate which retail internet service plans offered by Videotron and its affiliates include data caps and what those data caps are.
(CRTC)08Mar23-2-1b
Bell
- Using the templates provide in the initial question, provide per CMA and for the years 2018 through 2022 the average monthly number of residential Internet subscribers with stand-alone internet and the associated average monthly retail rate paid by those customers, as well as the average number of residential customers subscribed to a bundle that includes residential Internet and the associated average monthly retail rate paid.
- If data is not available at the CMA level, provide data at an appropriate lower level of aggregation that your company tracks (e.g. by postal code, central office, etc.). In such circumstances, provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level. Use the “Other” field in the templates. including a supplemental document if necessary, to indicate the level of aggregation used in providing the data, which should include all relevant assumptions, calculations, and details of the data sets used in the development of the table.
- Where the data cannot be provided in the specific manner requested by the templates, Bell is to provide its best approximation. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
Cogeco
- Provide the data by CMA where possible and, where that is not possible, use the templates included in the 8 March 2023 staff letter to provide data at an appropriate lower level of aggregation that your company tracks (e.g. by postal code, central office, etc.). Provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level. Use the “Other” field in the templates. including a supplemental document if necessary, to indicate the level of aggregation used in providing the data, which should include all relevant assumptions, calculations, and details of the data sets used in the development of the table.
- Where the data cannot be provided in the specific manner requested by the templates, Cogeco is to provide its best approximation. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
Rogers
- Resubmit all data in response to the question while adhering to the predefined speed tiers indicated within the templates.
- Rogers stated that it did not provide data prior to 2020 because of its inability to differentiate between HFC and FTTP. Rogers is to provide the 2018 and 2019 data at the most granular level of detail by technology available and clearly explain any limitations or assumptions with the data provided.
SaskTel
- Use the templates included in the 8 March 2023 staff letterto report the average monthly number of residential Internet subscribers per discount type, per speed tier and per year. If the data requested is not available, provide it at the next most appropriate level of granularity available and clearly explain any assumptions or limitations with the data provided.
(CRTC)08Mar23-3-1b
Bell
- Provide the data by CMA where possible and, where it is not possible, use the templates included in the 8 March 2023 staff letter to provide data at an appropriate lower level of aggregation that your company tracks (e.g. by postal code, central office, etc.). Provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level. Use the “Other” field in the templates. including a supplemental document if necessary, to indicate the level of aggregation used in providing the data, which should include all relevant assumptions, calculations, and details of the data sets used in the development of the table.
- Where the data cannot be provided in the specific manner requested by the templates, Bell is to provide its best approximation matching the template format. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
- Provide for the years 2018 through 2022 a supplemental table listing the average monthly number of residential Internet subscribers, including in the breakdown the total number of subscribers, the total number of new subscribers, and the total number of existing subscribers on promotional plans, at the most appropriate level of granularity possible. Include an average monthly retail Internet rate for each category, or where that is not possible provide the rate at the most appropriate level of granularity possible. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
Cogeco
- Provide the data by CMA where possible and, where that is not possible, use the templates included in the 8 March 2023 staff letter to provide data at an appropriate lower level of aggregation that your company tracks (e.g., by postal code, central office, etc.). Provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level. Use the “Other” field in the templates. including a supplemental document if necessary, to indicate the level of aggregation used in providing the data, which should include all relevant assumptions, calculations, and details of the data sets used in the development of the table.
- Where the data cannot be provided in exactly the way requested by the templates, Cogeco is to provide its best approximation. Provide clear and detailed explanations of any limitations or assumptions in the data provided.
Rogers
- Resubmit all data in response to the question while adhering to the predefined speed tiers indicated within the templates.
SaskTel
- SaskTel did not provide historical data in response to 3(c) through 3(e) because it stated that such historical data is not readily available. SaskTel is to provide 2018 through 2021 historical data in response to 3(c) through 3(e) at whatever level of detail is available and clearly explain any limitations or assumptions with the data provided.
Telus
- Where the data in response to 3(b) through 3(e) cannot be provided in the specific manner requested by the templates, Telus is to provide the data using its best approximation matching the template format. Provide clear and detailed explanations of any limitations or assumptions in the data provided.
- Provide for the years 2018 through 2022 a supplemental table listing the average monthly number of residential Internet subscribers, including in the breakdown the total number of subscribers, the total number of new subscribers, and the total number of existing subscribers on promotional plans, at the most appropriate level of granularity possible. Include an average monthly retail Internet rate for each category, or where that is not possible provide the rate at the most appropriate level of granularity possible. Provide clear and detailed explanations of any limitations or assumptions with the data provided.
(CRTC)08Mar23-4-1b
Telus
- On behalf of Altima, Telus provided responses to questions 4(a), 4(c), 4(e), and 4(g). The data answered each question in several different discrete ways. For example, in response to 4(a), Telus provided the data four times: by ILEC, then by province, then by speed, then by network.
- Telus is to re-file the Altima information in response to questions 4(a), 4(c), 4(e), and 4(g), presenting it at an appropriate level of granularity necessary to answer each question with a single set of data.
- Telus is encouraged to review how other parties, including themselves on behalf of Start, filed their responses in formatting the resubmission of Altima’s information.
Videotron to provide the requested information for VMedia.
(CRTC)08Mar23-5-1b
Videotron to provide the requested information for VMedia.
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