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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 17 January 2024

Our reference: 8740-B20-202301886, 8740-B20-202301902, 8740-S22-202301860, 8740-T66-202301927, 8740-T69-202301935

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Distribution List

Staff Letter - Telecom – Support Structure Service Tariff Notices (TN) – Requests for information

In TRP 2023-31,Footnote1 the Commission made a number of determinations to facilitate access to poles owned or controlled by the largest Canadian carriers. Accordingly, the Commission directed incumbent local exchange carriers (ILECs) to file, for its approval, revised tariff pages for their support structure service tariffs reflecting the Commission’s determinations in that decision.

On 3 April 2023, Bell Canada (Bell) filed TNs 977 and 978; TELUS Communications Inc. (TCI) filed TN 580 and 655;Footnote2 and Saskatchewan Telecommunications (SaskTel) filed TN 377.

The Commission received interventions from Bragg Communications Inc., Community Fibre Company, Independent Telecommunications Providers Association, Quebecor Media inc., Rogers Communications Canada Inc. and TekSavvy Solutions Inc. On 16 May 2023, Bell and TCI filed reply comments.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed. Commission staff considers that additional information is required from the parties to the proceedings in order to obtain a full and complete record.

As such, parties are requested to provide comprehensive answers, including rationale and any supporting information, to the attached request for information by 24 January 2024. On receipt of the responses, parties may file reply comments by 31 January 2024. Copies of the answers and reply comments should be sent to the other parties and to julie.boisvert@crtc.gc.ca.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on this webpage.

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

As set out in section 39 of the Telecommunications ActFootnote3and in IB 2010-961,Footnote4 persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Yours sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:  Julie Boisvert, CRTC, 819-953-2421, julie.boisvert@crtc.gc.ca

Distribution List

Bell Canada, bell.regulatory@bell.ca
Bragg Communications Inc., carrying on business as Eastlink, regulatory.matters@corp.eastlink.ca
Community Fibre Company, ben@communityfibre.ca
Independent Telecommunications Providers Association, regulatory@itpa.ca
Québecor Média inc., au nom de ses affiliées Vidéotron ltée et Freedom Mobile Inc., regaffairs@quebecor.com
Rogers Communications Canada Inc., regulatory@rci.rogers.com
Saskatchewan Telecommunications, document.control@sasktel.com
TekSavvy Solutions Inc., regulatory@teksavvy.ca
TELUS Communications Inc., regulatory.affairs@telus.com

Requests for information

In TRP 2023-31, the Commission determined that it was important to introduce a clear demarcation between the work required on poles to meet construction standards (corrective work) and all other types of make-ready work. Accordingly, at paragraph 40, ILECs were directed to revise their support structure service tariffs to include definitions of make-ready work and corrective work.

In the same decision, the Commission noted that support structure service tariffs contained limited provisions regarding timelines for ILECs for the processing of applications to access telecommunications poles, and none for the execution of make-ready work. The Commission considered that well-defined and clearly stated timelines would provide enhanced clarity and certainty to all parties and would be an efficient tool to prevent unjustified delays and their accompanying uncertainties and costs. Accordingly, the Commission directed ILECs to amend their support structure service tariffs to include timelines for make-ready work, as detailed in the tables at paragraph 119. However, the Commission did not establish timelines specific to corrective work, which, in the context of the tariff proceedings, has led to disagreements between parties about whether ‘corrective work’ was included in the definition of ‘make-ready work’. In particular, parties disagreed on whether the timelines established for make-ready work also apply to corrective work.

  1. Comment, with supporting rationale, on the possibility that the Commission will consider that the ‘make-ready work’ timelines also apply to the completion of ‘corrective work’. That is, where a timeline stipulates a certain number of days for the completion of make-ready work, both corrective and make-ready work should be completed within that time.
    1. Where multiple timelines could apply due to the requirement for both simple and complex work, comment, with supporting rationale, on whether:
      1. The longest timeline would apply; or
      2. Each type of work would need to be completed within the period appropriate for its type (simple or complex).
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