Telecom - Staff Letter addressed to the Distribution List

Ottawa–Gatineau, 29 January 2025

Reference: 1011-NOC2024-0235

BY EMAIL

Distribution List

Subject: Show cause and call for comments – Available footprint for Bell Mobility Inc. and TELUS Communications Inc.’s wholesale roaming services, Telecom Notice of Consultation CRTC 2024-235 - Requests for information

On 7 October 2024 the Commission initiated Show cause and call for comments – Available footprint for Bell Mobility Inc. and TELUS Communications Inc.’s wholesale roaming services, Telecom Notice of Consultation CRTC 2024-235.

To develop a fulsome record and assist the Commission’s assessment of the issues, the parties identified in Attachment 2 are asked to file responses to the questions set out in the attachment by 19 February 2025.

As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 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.

All documents must be received, and not merely sent, by the date indicated.

Sincerely,

Original signed by

Philippe Kent
Director, Telecommunications Services Policy
Telecommunications Sector

c.c.: Jeremy Lendvay, CRTC, 819-997-4946, Jeremy.Lendvay@crtc.gc.ca
Ethan Townsend, CRTC, 873-355-6698, Ethan.Townsend@crtc.gc.ca
Vish Iyer, CRTC, 873-353-3874, vish.iyer@crtc.gc.ca

Distribution List:

Questions for Bell Mobility Inc. (Bell) and TELUS Communications Inc. (TELUS)

101. Provide a copy of any Bell/TELUS radio access network (RAN) sharing agreement (often referred to as a network reciprocity agreement), including the Bell/TELUS Next Generation Network Reciprocity Agreement that was discussed in TELUS’ intervention at para. 3.
102. With respect to network traffic forecasts, TELUS noted at para. 27 of its intervention that “… Bell would not have insight into the expected traffic levels for its RAN, meaning it cannot undertake the necessary capacity planning to ensure network service and quality.” Provide the following information with respect to the forecasting of network traffic.
     1. Do Bell and TELUS currently exchange traffic forecasts with each other under their shared network agreement? If so, are separate traffic forecasts provided for each network generation? How are each others’ flanker brands accounted in the traffic forecasts?
     2. If the Commission were to require Bell and TELUS to provide access to the other company’s network for wholesale roaming, could any traffic forecast include the amount of traffic anticipated by such a requirement? If not, explain why not.
     3. With respect to wholesale mobile virtual network operator (MVNO) traffic forecasts (See Bell tariff item 101.12.(a) and TELUS item 235.3A 19.a.), how does your company manage capacity planning for traffic coming from wholesale customers subscribed to your network sharing partner’s MVNO access service? Could a similar capacity planning approach be used with respect to wholesale roaming traffic? If not, explain why not.
     4. Your company’s wholesale roaming tariff requires wholesale roaming customers to provide traffic forecasts (See Bell tariff item 100.10.(a) and TELUS item 233.3 14.). Comment on whether these provisions would need to be amended if the Commission were to mandate Bell and TELUS to provide access to the other company’s network for wholesale roaming. If so, provide details.

Questions for Rogers

201. Rogers’ wholesale MVNO access and wholesale roaming tariffs provide for access to its joint-build networks (See Rogers tariff item 800 1.19 definition of “Roaming Arrangement”; item 800 3.4; item 900 definition of “MVNO Arrangement.”; and item 902 1.3(a)). Please provide an overview of how Rogers handles capacity planning and network traffic forecasting when dealing with its network sharing partners.

Date modified:

2025-01-29