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Telecom - Staff Letter addressed to the Distribution List

Gatineau, 25 June 2025

Our references: 8740-C6-202404648, 8740-C6-202501981

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Distribution List

Subject: Procedural letter - Items filed under Tariff Notice (TN) 70 and Tariff Notice (TN) 71, New TPIA Speed Introduction - Deficiencies in Cogeco filings

On 01 October 2024, TekSavvy Solutions Inc. (“TekSavvy”) and the Competitive Network Operators of Canada (“CNOC”) together filed requests for disclosure of information filed in confidence and with deficiencies under TN 70 by Cogeco Communications Inc., on behalf of its subsidiary Cogeco Connexion Inc. (Cogeco).

Deficiencies

After careful review of the cost studies and the supporting documents filed, Commission staff is of the view that some filings from Cogeco were partial or incomplete. Remedying these deficiencies, which are identified in Attachment 2-A of this letter, will contribute to a fulsome record and allow for a better assessment of the matters at issue.

Process

Commission staff sets out the following process to address deficiencies in Cogeco’s filings.

Cogeco is to provide additional information as specified in Attachment 2-A of this letter, by 4 July 2025. The information is to be filed with the Commission and served on all parties in the attached distribution list.

Any party may submit comments with respect to the additional information filed by 11 July 2025, serving a copy to Cogeco. Cogeco may reply to any such comments by no later than 18 July 2025.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

Attach. (2):
Distribution List (1)
Outstanding deficiencies (2)

Distribution list:

  1. Cogeco, telecom.regulatory@cogeco.com;
  2. CNOC, regulatory@cnoc.ca;
  3. TekSavvy, regulatory@teksavvy.ca;
  4. Andy Kaplan-Myrth, TekSavvy, (akaplanmyrth@teksavvy.ca)
  5. Quebecor Media Inc., on behalf of Videotron Ltd. (regaffairs@quebecor.com)
  6. Patrick Desy, (patrick.desy@quebecor.com)
  7. Tacit Law Regulatory (regulatory@tacitlaw.com)

A - Deficiencies

  1. Refer to Telecom Decision 2023-196Footnote 1, paragraph 170, where it states:

    “When submitting rate-setting applications for any new or existing services, to enhance the Phase II methodology, wholesale service providers must provide market-level information, including the equivalent stand-alone retail rates, promotional and winback retail rates, comparison to rates for similar services in other countries, and any other relevant information, to allow the Commission to compare retail and wholesale rates and test the assumptions used in the rate-setting methodology and costing models.”

    Provide the following:

    1. Retail rates including those strictly for retention purposes (even if those have no equivalent advertised retail offering) for all the speed bands and service speeds introduced through TN 70 and TN 71.

  2. Refer to Cogeco’s TN 70 and TN 71, submitted August 28, 2024 and April 30, 2025, respectively:

    Provide the following:

    1. The serving areas where the newly introduced speed bands/tiers will be available on a retail and wholesale basis as well as the serving areas where the newly introduced speed bands/tiers will not be available on a retail and wholesale basis.

  3. Refer to Appendix 1 of Cogeco’s TN 70, submitted August 28, 2024, titled, “Cogeco TN70 - ABRIDGED - Appendix 1 Supporting Cost Tables”, tab titled, “Table 6a-Exp”.

    Provide the following:

    1. Include cost ‘causal to service’ and cost ‘causal to demand’ categorization in Table 6a-A, column “Key Reporting Cost Category”.
    2. Elaborate on the description given in Table 6a-A, column “Description” and column “Cost Driver Description”.

  4. Refer to Cogeco’s TN 70, submitted August 28, 2024. Also, refer to Commission Staff Letter dated 31 March 2016, Re: Information Associated with the Implementation of Telecom Decision CRTC 2016-117Footnote 2.

    Provide the following:

    1. Table 11;
    2. Table 12;
    3. Tables 13a-13d; and
    4. Table 14
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