Telecom - Staff Letter addressed to the Distribution list
Ottawa, 13 September 2024
Our reference: 1011-NOC2023-0056
BY EMAIL
Distribution list
Subject: Telecom Regulatory Policy CRTC 2024-180, Competition in Canada’s Internet service markets: Request for Revised Language and Process for Tariff Pages
On 13 August 2024, the Commission issued Telecom Regulatory Policy CRTC 2024-180 – Competition in Canada’s Internet service markets (TRP 2024-180), in which it mandated wholesale access to aggregated high-speed access (HSA) services, including over fibre-to-the-premises (FTTP) facilities. TRP 2024-180 established several service limitations and removed various pre-existing restrictions on aggregated HSA services.
TRP 2024-180 also required incumbents to file certain new tariff pages for approval with the Commission, while other tariff pages were simply to be updated and issued. This letter addresses the language used in the relevant tariff pages and outlines requests for incumbents on how to appropriately revise the newly issued tariff pages.
Commission staff is concerned that most of the incumbents have issued updated tariffs with language that does not properly give effect to the relevant Commission determinations. Issues identified by staff fall under the following three areas:
- Failure to define the term “incumbent”;
- Language that implies, rather than explicitly states, that affiliates of incumbents have incumbent or traditional serving territories; and
- Absence of language dealing with grandfathering of incumbent access to HSA services to serve end-users located in an incumbent’s traditional serving territory or language that fails to account for the 30-day grace period approved in TRP 2024-180.
Commission staff considers that the tariff language adopted by Bell Canada in Tariff Notice (TN) 7701, Proposed Tariff Page for General Tariff, CRTC 6716, Item 5460, in conjunction with the proposed definition of “incumbent” set out in paragraph 1(a)(11) of TN 7701, appropriately gives effect to the relevant Commission determinations.
Commission staff notes that these language issues are also present in the tariff pages that have been filed for approval. These tariffs will be dealt with by the Commission and may result in additional changes. Should any such modifications be considered relevant and appropriate for the issued tariff pages, additional process may be engaged.
Furthermore, several incumbents used incorrect process for the submission of new tariff pages. Specifically, Rogers Communications Canada Inc. (Rogers), Videotron Ltd. (Videotron), Shaw Cablesystems G.P. (Shaw), and Bragg Communications Incorporated, carrying on business as Eastlink (Eastlink) incorrectly filed new tariff pages, instead of issuing updated tariff pages.Footnote1 The process established in TRP 2024-180 regarding tariff pages for aggregated HSA services over FTTP is for incumbents to file for Commission approval. By contrast, the process for tariff pages for aggregated HSA services over all other access facilities apart from FTTP is to issue updated tariff pages.Footnote2
Accordingly, Commission staff requests:
- incumbents reissue the tariff pages in question with revised language that addresses the concerns in this letter by 20 September 2024; and
- parties that filed tariff notices incorrectly to withdraw their applications and to issue their tariff pages by 20 September 2024.
Commission staff considers that these tariff modifications would support the public interest for a timely implementation of TRP 2024-180.
Yours sincerely,
Original signed by
Philippe Kent
Director, Telecommunications Services Policy
Telecommunications Sector
c. c. Marianne Blais, CRTC, marianne.blais@crtc.gc.ca
Greg Lang, CRTC, greg.lang@crtc.gc.ca
Adam Mills, CRTC, adam.mills@crtc.gc.ca
Dan Mackwood, CRTC, daniel.mackwood@crtc.gc.ca
Attachment (1) Distribution list
Distribution List
Bell Canada, bell.regulatory@bell.ca;
CNOC, regulatory@cnoc.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;
TekSavvy, regulatory@teksavvy.ca;
Videotron, regaffairs@quebecor.com;
Xplore, cindy.wallace@xplore.ca;
Airnet Wireless Inc., jeptha@airnet.ca;
Allo Telecom, sac@allotelecom.ca;
Ampush, julian.reiche@gmail.com;
André’s Electronics, andre@andres1.com;
Beanfield, todd@beanfield.com;
Bravo Telecom, legal@bravotelecom.com;
British Columbia Broadband Association (BCBA), regulatory@bcba.ca;
Build Nova Scotia, david.finlayson@novascotia.ca;
Canadian Anti-Monopoly Project (CAMP), keldon@antimonopoly.ca;
Canadian Telecommunications Association, esmith@canadatelecoms.ca;
Carry Telecom, frankw@carrytel.ca;
CEDEC, john.buck@cedec.ca;
CIK Telecom Inc, jordan.d@ciktel.com;
Cinéma Péninsule Ltd, 397martin@gmail.com;
City Wide Communications, david@yourcitywide.com;
Coextro, skhandor@coextro.com;
Community Fibre Company, ben@communityfibre.ca;
Competition Bureau, conor.parson@cb-bc.gc.ca;
Competition Bureau, crtc2023-56@cb-bc.gc.ca;
CPC, campbell@campbellpatterson.com;
Cronomagic Canada Inc, bokhari@cronomagic.com;
Custom Communications, kelly.boyd@custom.ab.ca;
Devtel Communications Inc., devin@devtelcommunications.ca;
Eeyou Communications Network, trishtoso@gmail.com;
Execulink, regulatory@execulinktelecom.ca ;
Fédération des Coopératives de Câblodistribution et de télécommunication du Québéc (FCCTQ), fallaire@ressources.coop;
Federation of Canadian Municipalities, rrizzuto@fcm.ca;
Fibernetics Corporation, regulatory@fibernetics.ca;
First Mile Connectivity Consortium, info@firstmile.ca;
Frontier Networks, cgooey@frontiernetworks.ca;
IGS Hawkesbury Inc., jbogue@hawkmail.ca;
Intelligence Papineau Inc, odenis@ipapineau.tech;
John Roman, johnphiliproman@gmail.com;
Leepfrog Telecom, gchriss@leepfrogtelecom.com;
Lime Telenet, Ryan@limetelenet.com;
Manitoba Coalition, cacmb@mts.net;
Manitoba Coalition, chkla@legalaid.mb.ca;
Manitoba Coalition, kadil@legalaid.mb.ca;
Marc Nanni, mn_crtc@proton.me;
Mazagan Telecom, mazagantelecom@gmail.com;
Michel Mersereau, m.mersereau@utoronto.ca;
National Capital FreeNet, execdir@ncf.ca;
Netrevolution inc., drouleau@gtvr.com;
OpenMedia, erin@openmedia.org;
Public Interest Advocacy Centre, jlawford@piac.ca;
Secure by Design, kirk@secure-by-design.com;
Securenet, info@securenet.net;
SkyChoice Communications, serge@skychoice.ca;
Spectrum Telecom Group Ltd., ghatton@spectrumtelecom.ca;
Tbaytel, stephen.scofich@tbaytel.com;
Transat Telecom, aboulil@transattelecom.ca;
Truespeed Internet Services Inc., adam@truespeed.ca;
Vaxination Informatique, jfmezei@vaxination.ca;
Vaxxine Computer Systems Inc., president@vaxxine.com;
WaveDirect Telecommunications Limited, regulatory@wavedirect.org
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