Telecom - Staff Letter addressed to the Distribution List
Ottawa, 13 September 2024
References: 8740-R28-202304054, 8740-S9-202304070, 8740-V3-202304046, 1011-NOC2023-0056
BY EMAIL
Distribution List
Subject: Telecom Notice of Consultation 2023-56 – Approval of Québecor Média inc. on behalf of its affiliate Videotron’s Requests for an Extension to Deadline to Requests for Information
As part of the proceeding initiated by Notice of hearing – Review of the wholesale high-speed access service framework, Telecom Notice of Consultation 2023-56 (NoC 2023-56), dated 8 March 2023, the Commission directed wholesale high-speed access (HSA) service providers to file proposed tariffs and associated cost studies using the Phase II costing methodology, with supporting rationale, for fibre-to-the-premises facilities over aggregated wholesale HSA services, and to file new Phase II cost studies to establish rates for aggregated wholesale HSA services. The Commission received tariff applications, as well as supporting information, from the wholesale HSA service providers consistent with the Commission’s directions in NoC 2023-56.
On 22 August 2024, Commission staff requested additional information (RFIs) from certain wholesale HSA service providers in relation to their proposed tariffs, associated cost studies, and supporting rationale. Commission staff sent a revised version of the RFIs on 26 August 2024. Responses to these RFIs are due 20 September 2024.
On 3 September 2024, Québecor Média inc. on behalf of its affiliate Videotron (Videotron), requested to extend that deadline to reply to its RFI to 18 October 2024. Videotron stated that, as the amount of information requested through the RFI is significant and highly technical, considerable effort and additional time are required by Videotron’s internal teams to adequately respond to the questions.
On 4 September 2024, Rogers Communications Canada Inc. (Rogers) filed comments in support of Videotron’s request on similar grounds and asked for the same extension. Rogers also highlighted that the nature of the questions and scenarios in these RFIs are similar to those posed as part of the 2018 HSA proceeding related to the cable carrier cost studies. Rogers added that in the 2018 proceeding, companies were granted 10 weeks to respond to the RFIs as compared to 29 days for the current RFIs. Rogers submitted that a 4-week extension for responding to the RFIs should not impact the Commission’s timeline and would result in a better record for the establishment of just and reasonable rates.
On 9 September 2024, TekSavvy Solutions Inc. (TekSavvy) filed comments opposing the extension request submitted by Videotron and supported by Rogers. TekSavvy stressed that Videotron and Rogers have exaggerated the complexity and the volume of information requested in the RFIs and argued that running of the existing models with changes of inputs, parameters and assumptions should not be onerous. They added that, should the Commission agree that there is specific data or analysis that cannot reasonably be made available by the deadline, an extension could be granted for only that data or analysis.
Commission staff acknowledges that it has requested an extensive volume of information, some of which is highly technical. Commission staff notes that a complete record including the original cost study submission and the responses to the RFIs is necessary for an efficient analysis, as it reduces the likelihood of requiring numerous rounds of RFI which would help in the finalization of the rates on a timely basis. Therefore, singling out specific data and analysis for the extension as suggested by TekSavvy would be counterproductive. Commission staff is of the view that an extension would allow the cable carriers to provide the necessary high quality, comprehensive information required by the Commission in their responses to the RFIs without adding further delay to the Commission’s timelines.
Commission staff therefore approves Videotron and Rogers’ request to extend the due date for responses to 18 October 2024. This extension of the due date is also applicable to Shaw Cablesystems G.P.
Sincerely,
Original signed by
Chris Noonan
Director, Competitor Services and Costing Implementation
Telecommunications Sector
Distribution List
Company; Tariff Notice Number(s); Our Reference Number; Company Contact; Company Email
Rogers Communications Canada Inc.; 0079; 8740-R28-202304054; regulatory@rci.rogers.com
Shaw Cablesystems G.P.; 0042; 8740-S9-202304070; Regulatory@sjrb.ca;
Videotron; 0063; 8740-V3-202304046; regaffairs@quebecor.com;
Bell Canada; bell.regulatory@bell.ca;
TELUS Communications Inc.; regulatory.affairs@telus.com,
Saskatchewan Telecommunications; W.N. (Bill) Beckman; document.control@sasktel.com;
Cogeco, telecom.regulatory@cogeco.com;
Eastlink, regulatory.matters@corp.eastlink.ca;
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, regulatory@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
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