ARCHIVED -  Telecom Decision CRTC 92-6

This page has been archived on the Web

Information identified as archived on the Web is for reference, research or recordkeeping purposes. Archived Decisions, Notices and Orders (DNOs) remain in effect except to the extent they are amended or reversed by the Commission, a court, or the government. The text of archived information has not been altered or updated after the date of archiving. Changes to DNOs are published as “dashes” to the original DNO number. Web pages that are archived on the Web are not subject to the Government of Canada Web Standards. As per the Communications Policy of the Government of Canada, you can request alternate formats by contacting us.

TELECOM DECISION
Ottawa, 1 May 1992
Telecom Decision CRTC 92-6
BELL CANADA AND NORTHWESTEL INC. - SALE OF FACILITIES IN THE NORTHWEST TERRITORIES
I BACKGROUND
On 8 July 1991, the Commission received applications from Bell Canada (Bell) and Northwestel Inc. (Northwestel) related to the proposed transfer to Northwestel of substantially all of Bell's assets in the eastern portion of the Northwest Territories (eastern NWT). Bell's application was filed pursuant to subsection 11(2) of the Bell Canada Act, which provides that:
Except in the ordinary course of the business of the Company, no facilities of the Company that are integral and necessary for the carrying on of telecommunications activities shall be sold, leased, loaned or otherwise disposed of without the prior approval of the Commission.
Bell proposed to transfer these assets to Northwestel at their net book value. Bell proposed to provide total compensation of $18,420,000 to Northwestel in recognition of the net loss associated with these assets. Bell calculated this compensation as the present value, after certain deductions, of the net loss that Bell estimated it would incur over the ten year period beginning 1 January 1992, if it were to continue operating in the Northwest Territories.
Under the terms of the proposed sale, Bell would transfer the assets and liabilities associated with its operations in the Northwest Territories to Northwestel at their estimated net book value of $17,967,000, which Bell stated is also the fair market value, as of 1 January 1992. The transaction would also entail a cash payment to Northwestel of $453,000, the difference between the estimated compensation of $18,420,000 and the net book value of the assets and liabilities to be transferred.
Bell proposed to account for this transaction by creating a deferred charge of $18,420,000, which it proposed to amortize against income over the ten year period from 1992 to 2001. Northwestel proposed to establish a corresponding deferred credit of $18,420,000 and to amortize this credit to income over the same period.
In addition, Bell submitted for the Commission's approval an Interconnection and Settlement Agreement, providing for the settlement of revenues between the two companies on the basis of the Commission and Prorate method. Bell stated that the proposed agreement is similar to those in place between Bell and various other independent telephone companies.
In conjunction with the proposed transfer of assets, Northwestel filed Tariff Notice 403, proposing tariff revisions that would permit it to provide service to the 22 exchanges in the eastern NWT now served by Bell. Tariff Notice 403 also proposed rate revisions applicable to Northwestel's present operating territory.
In Bell Canada and Northwestel Inc. - Sale of Facilities in the Northwest Territories, CRTC Telecom Public Notice 1991-61, 2 August 1991, the Commission initiated a proceeding to consider the issues raised by these applications. The following parties participated in this proceeding: Canadian Business Telecommunications Alliance; Government of the Northwest Territories (GNWT); Government of Yukon (Yukon); Inuit Tapirisat of Canada (ITC); Mr. Dan Lang, Leader of the Official Opposition of the Yukon Legislative Assembly; Municipality of Iqaluit; Telesat Canada (Telesat); Thorne Little Chartered Accountants; and Unitel Communications Inc. The Commission, Yukon and ITC addressed interrogatories to both Bell and Northwestel, while GNWT addressed interrogatories only to Northwestel. Yukon, Telesat and Mr. Dan Lang filed comments on the applications. In addition, the Commission received letters from Mr. Kenn Harper, the Iqaluit Chamber of Commerce and the Municipality of Rankin Inlet, as well as a letter from Mr. Stuart Kennedy, who enclosed a petition signed by 200 citizens of the eastern NWT.
II PROPOSED BENEFITS, TERMS AND CONDITIONS
A. General
In its application, Bell stated that the completion of this transaction would make Northwestel the operating telephone company for the entire region of the Yukon and Northwest Territories, thus achieving certain operational efficiencies and benefits. Bell stated that the transaction has been structured so as to ensure that Bell's customers in Ontario and Quebec are essentially neither beneficially nor adversely affected, while at the same time providing Northwestel and customers with the various benefits and advantages that would result from the integration of operations for the entire region.
In Tariff Notice 403, Northwestel stated that its application was guided by the following principles:
(1) customers in Northwestel's existing territory and in the eastern NWT will benefit from the integration of the operating areas; and
(2) there will be no significant cross flow of service revenues between Northwestel's existing territory and the eastern NWT.
In Northwestel's view, its focus and expertise in northern operations place it in an ideal position to provide service that best meets the needs of the small, isolated communities of the eastern NWT. The company anticipated the following benefits associated with the proposed sale:
(1) the ability to provide additional services to bothexisting customers of Northwestel and to customers in the eastern NWT, due to the expanded customer base and the resulting increase in efficiency;
(2) the advancement of reductions in long distance rates for existing customers;
(3) a reduction in the administrative requirements faced by customers such as GNWT, who have communications needs throughout the Northwest Territories;
(4) a commitment to an accelerated modernization program in the eastern NWT;
(5) the expansion of local employment and improved access to customer service through implementation in the eastern NWT of Northwestel's community worker program; and
(6) the expansion of the community agencies network in all communities in the eastern NWT not now having a telephone company presence.
As well, Northwestel submitted that one company, exclusively focused on the north, would enhance the ability of territorial governments, the federal government and the Commission to develop and implement policies tailored to northern concerns and problems.
Northwestel also proposed an immediate equalization of local and competitive service rates between the two operating territories and a gradual equalization of long distance rates, as permitted by its financial performance.
Other than the Municipality of Rankin Inlet and Mr. Stuart Kennedy, no interveners specifically opposed the transfer of assets. Rather, concerns centred on the terms and conditions of the transfer of assets, the quality of service in the eastern NWT and the potential rate increases associated with the transaction. These and other issues are discussed below.
B. Valuation of Assets and Liabilities
None of the interveners commented on Bell's valuation of the assets, which consist primarily of telecommunications plant and equipment. The Commission notes that the valuation of these assets at their net book value is consistent with the Commission's determination in Bell Canada - Review of Revenue Requirements for the Years 1985, 1986 and 1987, Telecom Decision CRTC 86-17, 14 October 1986. In that Decision, the Commission determined that "...where it is neither feasible nor practical to determine the fair market value of assets, as in the case of assets such as plant and equipment, the assets will be transferred at net book value." In the Commission's view, Bell's valuation of these assets at their net book value is appropriate.
C. Estimation of Compensation
1. General
Bell submitted that the amount of compensation represents the net loss, in present value terms, that it would expect to incur over the ten year period beginning 1 January 1992, if it were to continue to operate in the Northwest Territories, after deducting (1) the present value of the amount of settlement revenues that Northwestel would receive from Bell over this period as a result of this transaction, and (2) the portion of satellite costs that Bell would continue to incur in order to interconnect with Northwestel under the proposed Interconnection and Settlement Agreement.
Bell and Northwestel considered that the amount of compensation is appropriate to ensure that Northwestel is not faced with a substantial additional revenue requirement upon completion of the sale. In addition, Bell's remaining customers in Ontario and Quebec would not be adversely affected, since they would otherwise have been required to continue to bear the effects of Bell's losses from these operations if the transaction were not completed.
2. Underlying Assumptions
In calculating the compensation of $18,420,000, Bell prepared pro forma income statements for the ten year period commencing 1 January 1992 for its operations in the eastern NWT based on several assumptions regarding revenues, expenses and finance.
Yukon questioned Bell's assumptions regarding revenue growth, expense growth and rate of return on average common equity (ROE). Yukon stated that the use of different assumptions for these factors produces an increase of $12.9 million in the required compensation. On this basis, Yukon submitted that the compensation should be increased.
The Commission has reviewed the underlying assumptions used by Bell to estimate the amount of compensation. In the Commission's view, little evidence has been introduced to suggest that these assumptions are not reasonable. The Commission notes that the assumptions regarding demand and revenue growth are generally slightly below historical averages for the eastern NWT. The Commission also considers that the remaining assumptions (i.e., expense growth and finance) used by Bell to estimate the amount of compensation, other than as noted below regarding satellite rates, are reasonable and appropriate.
The proceeding initiated by Telesat Canada - General and Interim Rate Increases for Space Segment Services, Phase III Costing Manual, Applications to Review and Vary Certain Portions of Telecom Decision CRTC 90-28, CRTC Telecom Public Notice 1991-89, 24 December 1991 (Public Notice 1991-89) will determine the final rates for Telesat's Space Segment Services. In the Commission's view, any determinations with respect to rates to be charged for satellite servicesmade in that proceeding should be used in the calculation of the compensation.
3. Satellite Savings Program
A portion of total operating expenses over the study period is related to satellite costs associated with Bell's contract with Telesat to lease 22 earth stations in the eastern NWT. In calculating the compensation, an amount was estimated to reflect a satellite savings program that would gradually replace the leased earth stations with owned earth stations over a ten year period starting in 1992.
Bell stated that the satellite savings program was not assumed to involve the purchase of earth stations currently leased from Telesat. Bell stated that many of these earth stations would have little or no useful life left at the scheduled time of replacement.
Telesat expressed concerns related to the investment that it has made over the years in building an earth station network to accommodate Bell's requirements in the eastern NWT. Telesat stated that it did not understand Bell's assertion that many of these earth stations would have little or no useful life left at the scheduled time of replacement. Telesat submitted thatvery little deterioration occurs to the equipment, once installed. Telesat argued that replacing an existing earth station infrastructure with new and more expensive facilities would necessarily result in higher rates for services to northern communities.
In reply, Bell stated that the gradual replacement of leased earth stations with owned earth stations was intended to reduce overall expenses in the eastern NWT. Bell stated that each earth station to be replaced would have been in service for 15 to 20 years. Bell submitted that replacement parts for defective components and additional equipment needed to meet growth requirements have been discontinued by the manufacturer. In addition, Bell stated that new technology currently available can increase efficiency through reducing transponder usage and overall earth station maintenance. Therefore, Bell submitted that its assumption regarding the gradual replacement of these earth stations is reasonable.
In the Commission's view, it is reasonable, for the purposes of calculating the amount of compensation, to assume a gradual replacement of these leased earth stations, in order to increase operational efficiency, over the study period. Furthermore, in the Commission's view, the financial projections regarding the satellite savings program are reasonable and appropriate.
D. Access to Service
No intervener expressed concern regarding the access to service in either the eastern NWT or Northwestel's existing territory. Northwestel submitted that the access to service now enjoyed by Northwestel subscribers in the company's existing territory would not be diminished.
Bell provides certain services in Inuktitut in each of the 22 eastern NWT communities. Northwestel stated that it would not remove current services and that it would examine the feasibility of enhancing services in Inuktitut in the eastern NWT.
Northwestel's plans to continue to provide Bell Message Relay Service (MRS) to customers in the eastern NWT. While Bell would operate the relay service, inquiries and complaints related to MRS would be directed to Northwestel.
Northwestel also plans to continue to offer current discounts for users of Telecommunications Devices for the Deaf (TDDs) in the eastern NWT, as well as the calling card discount now offered to disabled subscribers in that region. Northwestel stated that it plans to examine the extension of these discounts as it moves to equalize long distance rates between the eastern NWT and its existing territory.
Northwestel stated that it would not object to providing various other services now available to disabled subscribers in the eastern NWT, if there is a demand for the services and if the equipment is available. Bell identified five types of service, equipment and discounts (other than MRS and those relating to TDDs) for which there is a demand by disabled subscribers in the eastern NWT. Northwestel currently provides one of these services in its existing territory.
Northwestel plans to establish part-time community workers and community agencies in all communities in the eastern NWT without a telephone company presence. The company anticipated that it would take two years from the effective date of Commission approval to achieve this goal. Northwestel submitted that this plan would expand local employment and improve access to customer service.
In the Commission's view, the level of access to service now available to residents of the eastern NWT will not be diminished if the sale is approved. In addition, the Commission notes Northwestel's willingness to provide access to other services currently offered to disabled subscribers in the eastern NWT, where there is demand for the service and where the equipment is available.
E. Quality of Service
Various parties submitted that the quality of service in the eastern NWT, served by Bell, is superior to that in the western Arctic, served by Northwestel, and that the quality of service in the eastern NWT would decline if the sale is approved.
Northwestel stated that it is committed to maintaining Bell's current quality of service standards in the eastern NWT and to working with the Commission to develop one set of standards that would be applied uniformly throughout its operating territory.
The Commission notes that Bell files quarterly reports on quality of service and that, for 1990 and 1991, all quality of service standards were met, with the exception of one standard for one month. In the Commission's view, the continued reporting and adherence to the current standards would allow the Commission to ensure that existing levels of service are maintained in the eastern NWT.
The Commission considers that Northwestel's commitment to developing one set of standards should ensure that, if the sale is approved, subscribers in both operating territories will receive acceptable service, measured consistently with an approved common set of standards.
F. Interconnection and Settlement Agreement
No intervener commented on the proposed interconnection and settlement agreement. The Commission notes that the agreement is similar to those in place between Bell and both Québec Téléphone and Télébec. The Commission has reviewed the proposed agreement and considers that the terms and conditions are fair and reasonable.
G. Rate Proposals
Northwestel proposed tariff revisions, effective 1 January 1992, providing for the provision of service to 22 exchanges in the eastern NWT and for certain rate adjustments.
Northwestel proposed immediate equalization of all local and competitive service rates between its existing operating area and the eastern NWT. The company also proposed to bring intra-company long distance rates in the two areas closer together as part of a gradual move towards long distance rate equalization. The company stated that it would propose further Message Toll Service (MTS) rate adjustments, moving toward rate equalization, as its financial results permit, while minimizing the impact on customers with respect to other rates. The company also proposed to grandfather all services currently offered by Bell in the eastern NWT that are not provided by Northwestel.
Northwestel estimated that the average monthly residential bill (including access, toll, and equipment rental charges) would decrease by $0.24 for existing Northwestel subscribers and would increase by $0.11 for subscribers in the eastern NWT. Northwestel estimated that the average monthly business bill (including access, toll, and equipment rental charges) would decrease by $2.71 for existing Northwestel subscribers and increase by $0.97 for subscribers in the eastern NWT.
Yukon expressed concern that the application might result in a succession of local rate increases, as well as delays in MTS rate reductions, should Northwestel's projections prove to be optimistic. Yukon opposed any increases that could be construed as a subsidy by the company's existing territory of the company's purchase of the eastern NWT. Other interveners expressed concerns over increases in access charges and possible long distance rate increases.
In the Commission's view, Northwestel's proposal for immediate equalization of both the local and competitive service rates between the two areas is reasonable. The Commission considers that the restructuring, as proposed, would result in a minimal cross flow of revenues between Northwestel's existing territory and the eastern NWT. The Commission agrees that the current disparity between Northwestel's and Bell's MTS rates is too great to make all MTS schedules uniform immediately.
The Commission considers that Northwestel's proposal to grandfather all services currently offered by Bell, but not by Northwestel, is appropriate, with one exception. Northwestel does not currently have tariffed rates for Cable Support Services. The company has indicated that there are currently nine customers in the eastern NWT who obtain Cable Support Services from Bell. In the Commission's view, it would not be appropriate to grandfather Cable Support Services without providing the opportunity for potentially affected customers to comment on the proposal.
H. Disposition
The Commission agrees that certain operational efficiencies and benefits can be achieved by having one company provide service for the entire region. The Commission also agrees that proposals put forward in the applications have been structured to ensure that there is no significant cross flow of revenues between Northwestel's existing area and the eastern NWT. The Commission also considers that the concerns expressed by several parties regarding the terms and conditions of the transfer of assets, quality of service and rates have been adequately addressed in this proceeding or will be addressed by the Commission in the future, as discussed below. Accordingly, the Commission finds the proposed transfer of assets from Bell to Northwestel to be in the public interest. Therefore, the Commission approves the sale of substantially all of Bell's assets in the eastern NWT to Northwestel.
The carriers are directed to complete the transfer by 1 July 1992. Should Bell and Northwestel wish to transfer the assets at an earlier date, they are to inform the Commission of their intentions. The effective date of the transfer shall become the valuation date. The following terms and conditions will apply to the transfer:
(1) the valuation of the assets shall be the net book value on the effective date;
(2) the method and the assumptions used in Bell's application to calculate the estimated compensation, except as discussed in (3) below, shall be used to estimate the revised compensation for the ten year period following the effective date; and
(3) rates for Space Segment Services, used in determining the amount of compensation, shall be based on the rates determined in the proceeding announced in Public Notice 1991-89.
Bell is directed to file for final approval, by 31 October 1992, a revised estimate of the valuation of the assets and compensation, in the format of Attachments 3 and 4 to its application of 8 July 1991, based on the determinations above.
Northwestel is directed to provide service offerings and discounts equivalent to those for which Bell identified demand by disabled subscribers in the eastern NWT.
The existing frameworks for each operating territory for measuring quality of service are to remain in place and results are to be reported by Northwestel separately for the eastern NWT and for Northwestel's existing territory, until a uniform set of standards is in place for the combined operating territory.
The Commission hereby approves the Interconnection and Settlement Agreement.
The Commission also approves Bell's proposal that current tariffed MTS rates and conditions continue to apply to customers in Ontario and Quebec regarding calls made to the 22 exchanges to be transferred to Northwestel. The Commission approves the tariff revisions proposed under Northwestel Tariff Notices 403, 403A, 403B, 403C, 403D and 403E, with the exception of those revisions related to the grandfathering of Cable Support Services, as of the effective date of the transfer. The Commission will initiate a separate proceeding in the near future to consider the rates, terms and conditions under which Northwestel should make Cable Support Services available in the future.
III OTHER MATTERS
A. Amortization of Deferred Charge/Credit
Bell proposed to establish a deferred charge equal to the amount of compensation and to amortize it against income over a ten year period commencing the date of the transfer. Bell's proposed amortization schedule was based on the present value of the projected net losses in each given year. No intervener commented on Bell's proposed amortization schedule. The Commission concludes that Bell's method of determining its amortization schedule is appropriate and directs Bell to file, by 30 October 1992, a revised amortization schedule based on the determinations in this Decision.
Northwestel planned to establish a credit equal to the amount of compensation and to amortize it to income over the same ten year period. However, Northwestel's proposed schedule of amortization was different from Bell's proposed schedule. Northwestel stated that its amortization schedule was determined by amortizing the deferred credits in annual amounts that would produce an allowable ROE of 14%, taking into consideration the company's accelerated capital program, changes in operations, and the impact on the company's revenue requirements.
Yukon was concerned about the potential cross-subsidization of the eastern NWT by Northwestel's existing operating territory. Yukon argued that Northwestel should be required to account for eastern NWT revenues and expenses separately forat least five years in order to ensure that no cross-subsidization occurs.
In reply, Northwestel submitted that it is not in the public interest to account for the eastern NWT operations separately from its existing operations. The company submitted that the added expense of an internal tracking system outweighs any marginal benefits that might accrue from such a system.
The Commission notes that, for the purposes of this application, Northwestel estimated the revenue requirement impact associated with its projected losses in the eastern NWT to be approximately $2.9 million for 1992 and $3.6 million for 1993. In the Commission's view, the specific identification of these losses in later years by maintaining separate accounting systems would be too costly and onerous. The Commission agrees with Northwestel that the company should not be required to maintain separate accounting systems for the two operating territories.
However, with respect to Northwestel's proposed amortization schedule, the Commission notes that the deferred credit was established to offset anticipated losses associated with operations in the eastern NWT. The specific amount of future losses will depend on factors such as:
(1) the timing of modernization of switching facilities and replacement of leased earth stations (i.e., expenditures and cost savings);
(2) the impact of possible future rate changes; and
(3) changes in the company's revenue requirement.
Given the magnitude of the projected loss in proportion to current operations and the uncertainties and lack of details regarding the issues raised above, the Commission considers it inappropriate to approve Northwestel's proposed ten year amortization schedule in advance. Rather, the Commission considers that the appropriate amount of the deferred credit to be amortized in a given year should be determined annually based on the underlying assumptions included in the company's forecast for that year. The Commission considers that matters such as quality of service and access to service should also be considered. While the company is not required to maintain separate accounting records for the two territories, the Commission considers it in the public interest that the company be able to provide its best estimates regarding certain information with respect to the eastern NWT.
Therefore, by no later than 31 December of each year, Northwestel is required to apply to the Commission to amortize to income the portion of its deferred credit that it considers appropriate for the following year. This application should be supported by theunderlying assumptions used to derive the proposed amount to be amortized. Such information should include the company's financial forecasts for that year, details regarding planned capital expenditures and expected cost savings in the eastern NWT, projected operating income or loss from eastern NWT operations, and planned tariff filings for both operating territories. The Commission will consider what action or further process, if any, is required after receiving the company's application.
The Commission notes that, for 1992, the company projected an increase in its revenue requirement of approximately $2.9 million associated with an operating loss for eastern NWT operations. Therefore, the Commission permits Northwestel to amortize $1.45 million of the deferred credit for the remaining portion of 1992.
B. Resale and Sharing Rules Applicable to the Eastern NWT
In Tariff Revisions Related to Resale and Sharing, Telecom Decision CRTC 87-2, 12 February 1987 (Decision 87-2), the Commission established rules governing the resale and sharing of certain services of the carriers then under its jurisdiction, including Bell and Northwestel. In Resale and Sharing of Private Line Services, Telecom Decision CRTC 90-3, 1 March 1990 (Decision 90-3), the Commission amended the resale and sharing rules established in Decision 87-2 for Bell and other companies, but not for Northwestel. The Commission determined that it was inappropriate at that time to alter the Decision 87-2 rules in Northwestel's operating territory, given the differences between Northwestel's circumstances and those of the other carriers (differences due to operating conditions in the north), the lack of information regarding the impact on revenue and contribution erosion, and the absence of demand to alter the Decision 87-2 rules in Northwestel's operating territory.
Northwestel submitted that the public interest would be best served by applying the Decision 87-2 rules in the eastern NWT. Northwestel stated that the circumstances in its existing operating territory are paralleled in the eastern NWT. Bell stated that it is not aware of any reseller or sharing group operating in the eastern NWT for voice services. No intervener commented on this issue.
The Commission agrees with Northwestel that the circumstances that contributed to the Commission's decision not to extend the rules established in Decision 90-3 to Northwestel's territory also exist in the eastern NWT. Furthermore, in view of Bell's statement that it is not aware of any reseller or sharing group operating in the eastern NWT for voice services, it is the Commission's view that no person would be prejudiced by applying the Decision 87-2 rules in the eastern NWT. Therefore, the Commissiondirects Northwestel to apply the Decision 87-2 rules in the eastern NWT.
C. Depreciation Practices
The Commission notes that Northwestel has not filed a depreciation study with the Commission since 1986. During a recent depreciation audit, Commission staff noted that Northwestel's depreciation rates have not been technically updated since that time. Northwestel is therefore directed to complete a full depreciation study of the assets in its existing operating territory, prior to the effective date of the transfer, in compliance with the Commission's directives on depreciation, and to file this study with the Commission by 4 August 1992. Bell is directed to file, by 3 June 1992, the most recent depreciation study of its assets in the eastern NWT. A copy is to be served on Northwestel by the same date. The Commission also directs Northwestel to file a full depreciation study of the combined assets by 4 August 1992.
D. Construction Program Review
In Tariff Notice 403, Northwestel estimated that its construction expenditures would increase by $12.6 million in 1992 and $9.3 million in 1993 as a result of the acquisition of Bell's assets in the eastern NWT. Northwestel proposed to replace three mechanical exchanges in the eastern NWT in 1992 at an estimated cost of $1.6 million, followed by five in 1993 at a total estimated cost of $2.2 million. The company also plans to replace 13 earth stations in 1992 at a cost of $7.4 million and nine earth stations in 1993 at a cost of $4.8 million.
Telesat stated that it had offered to sell to Northwestel its earth stations in the eastern NWT for an amount equivalent to their net book value plus a small percentage. Telesat considered that this amount was approximately half of the amount that Northwestel would have to incur to replace these assets with new facilities. Telesat stated that Northwestel's counter-offer amounted to a fraction of the equipment's net worth.
In reply, Northwestel stated that it would have to replace the existing Telesat equipment with new technology in the future for the purpose of increasing quality of service.
The Commission notes that Northwestel intends to provide further details for the years 1992 to 1996 in the proceeding announced in Northwestel Inc. - 1992 Construction Program Review, Telecom Public Notice CRTC 92-4, 10 February 1992. The Commission intends to review Northwestel's modernization plans for the eastern NWT in the context of that proceeding.
E. Filing of Tariffs
Bell and Northwestel are directed to issue, no later than seven days prior to the effective date of the transfer, final tariff pages giving effect to the tariff revisions resulting from this Decision.
Allan J. Darling
Secretary General
Date modified: