ARCHIVED - Order CRTC 2001-833

Order CRTC 2001-833

Ottawa, 15 November 2001

CRTC approves proposal to phase out Bell Neutral Answer Service

Reference: Tariff notices 6578 and 6578A

Summary

By February 2003, Bell Canada will no longer provide the Bell Neutral Answer Service (BNAS). Through BNAS, Bell Canada operators answer 9-1-1 calls and ensure they are transferred to the appropriate emergency service agency. BNAS was introduced in 1994, but many original municipal BNAS customers now operate their own call centres. For this reason, among others, Bell Canada argued that it is no longer economically feasible to continue offering the service. However, Bell Canada noted that it will help its municipal customers find alternatives to BNAS.

Background

1.

The Commission approved the Bell Neutral Answer Service (BNAS) in 1994. The service was intended to provide, on an optional basis, a centralized point to answer 9-1-1 calls on behalf of municipalities that needed an alternative to providing their own public safety answering points (PSAPs).

2.

The BNAS is staffed and operated by Bell Canada operators. When an operator receives a 9-1-1 call, the operator determines the nature of the emergency and redirects the call to the appropriate emergency agency (i.e., fire or police department, or ambulance service). The operator maintains responsibility for the call until the emergency agency representative starts speaking to the caller.

Bell Canada's application

3.

On 6 April 2001, Bell Canada filed tariff notice 6578, which proposed to destandardize BNAS effective 2 July 2001 and to withdraw the service in its entirety no later than February 2003.

4.

In Appendix A of the attachment to TN 6578, Bell Canada provided, in confidence, a list of BNAS customers. The list included the expiration dates of the BNAS agreements with these customers.

5.

On 19 October 2001, Bell Canada, under TN 6578A, filed a revised Appendix A. Where appropriate, the company added information noting the dates when customers would migrate to alternate service providers.

6.

Bell Canada noted that, originally, it invested in BNAS because it saw a demand for a service that would complement the 9-1-1 Public Emergency Reporting Service (PERS). At that time, the local services market offered limited competitive alternatives.

7.

Bell Canada indicated that, since 1994, both the advent of call-centre technology in a competitive environment and the growth of other 9-1-1 related answering businesses have provided attractive alternatives to BNAS.

8.

In addition, Bell Canada noted that these factors and municipal restructuring have prompted many original municipal customers to operate their own call centres. Many answering bureaus have also started operations and these bureaus offer lower rates.

9.

As a result, Bell Canada submitted that the demand for BNAS is much lower than previously projected.

10.

Bell Canada also submitted that it considered alternatives to the proposed withdrawal of BNAS. These alternatives included rate increases and alternate serving structures. However, from a company and customer perspective, the size of the rate increases and the technical restructuring costs were not viable.

11.

Bell Canada concluded that it does not make economic sense for the company to continue to offer BNAS.

12.

Bell Canada submitted that efforts have been taken to provide a smooth transition plan and to minimize any perceived effects on customers. All existing contracts will be honoured and appropriate notifications have been provided in the cases of new and/or renewable agreements.

13.

Bell Canada stated that, beginning on 2 July 2001, the requested date for destandardization, it would:

Comments from parties

14.

The parties that objected to Bell Canada's proposal submitted that the proposal would result in projected higher operating costs and extensive transition costs. In addition, the County of Simcoe submitted that Commission approval of the application would be seen as the critical first step in the dismantling of the entire Ontario 9-1-1 network.

15.

The Association of Municipalities of Ontario (AMO) and the Ontario 9-1-1 Advisory Board (OAB) proposed that changes should be made to the timeframe proposed by Bell Canada if the Commission approves the application. The timeframe changes proposed by AMO and OAB are noted in paragraph 26.

Financial impact on parties

16.

The County of Simcoe stated that if it elected to deliver directly the Central Emergency Reporting Bureau (CERB) services, its annual CERB costs would increase by 107% to $507,000 per year, based on increased personnel and system operating equipment costs.

17.

Bell Canada stated, in its reply comments, that the County of Simcoe had assumed that it would need to staff its own 9-1-1 back-up answering bureau, rather than contracting with a competitive alternate service provider.

18.

Bell Canada noted that according to comments the company received, former BNAS customers were able to reduce costs through alternative service arrangements.

Impact on Ontario 9-1-1 network

19.

With respect to the County of Simcoe's submission that the withdrawal of BNAS would be seen as the first step in the dismantling of the Ontario 9-1-1 network, Bell Canada replied that such a perception would have no basis in fact. According to Bell Canada, the application relates solely to BNAS, which was designed and provisioned as a complement to 9-1-1 and as a fully competitive service that offered an alternative back-up answering location for 9-1-1 calls. Bell Canada stated that BNAS has always been offered on the basis that a municipality could use alternative 9-1-1 call answering arrangements.

20.

Bell Canada further stated that the BNAS portion of 9-1-1 service that is the subject of this proceeding is not the 9-1-1 PERS network. Bell Canada will continue to fully support and provision PERS in its operating territory.

Proposed timeframe

21.

The AMO and the OAB submitted that, if the Commission does not deny Bell Canada's application, they need to ensure that affected municipalities will have a reasonable transition time.

22.

The AMO and OAB stated that the renewal of the BNAS agreements on a monthly basis is cumbersome and is not consistent with most municipal contracting processes.

23.

The AMO and OAB further submitted that, once a municipality decides on a BNAS alternative, significant work and co-ordinated activity will be needed to re-configure a municipality's 9-1-1 network to route calls to an alternative provider.

24.

The AMO and OAB stated that the associated planning and budgeting processes are complex and are known to take several years at best to develop and implement.

25.

In addition, the AMO and OAB stated that many Ontario municipalities are not aware of the choices available to them. These municipalities have never needed, prior to this application, to seek alternatives. According to the AMO and OAB, these municipalities will need more time to locate alternatives and assess them on the basis of the needs of their communities and local emergency agencies, as well as the cost implications.

26.

Accordingly, the AMO and OAB requested the following changes:

27.

In reply, Bell Canada stated that, in consideration of the lead times required for seamless migration of existing BNAS systems to available competitive alternatives to BNAS, Bell Canada undertook and completed a mail notification program to its existing customer base in March 2001. The notification program included personal follow-ups by Bell Canada 9-1-1 service personnel to ensure that its customers would be aware of its intentions before it filed TN 6578 with the Commission.

28.

Bell Canada submitted that the concerns expressed by the AMO and OAB vastly overstate the work associated with the conversion from BNAS to alternative serving arrangements. Bell Canada noted that many municipalities have already migrated from BNAS to alternative serving arrangements. These migrations have, for the most part, taken less than three months to complete and customer expectations have been met.

29.

Bell Canada further stated that it is not suggesting a re-negotiation of the contracts every month, but simply a date-change as required on the month-to-month basis.

30.

In its application, Bell Canada proposed to provide customers with assistance in the migration process. Some parties requested further information regarding the nature of the assistance. Bell Canada stated that the assistance will include:

Conclusion

31.

The Commission finds that the approval of the application to withdraw BNAS would have no effect on the operation of 9-1-1 service in Ontario. The BNAS portion of 9-1-1 service that is addressed with this proposal is not the 9-1-1 PERS network that Bell Canada continues to support and provision.

32.

The Commission notes that in TN 6578A, Bell Canada indicated that, by year-end, the number of BNAS subscribers will have declined by 32% since TN 6578 was filed. In addition, seven other BNAS customers are seeking answering alternatives and two others are expected to set up their own answer bureau.

33.

The Commission finds that the interested parties have not demonstrated that there is sufficient justification to require Bell Canada to continue to provide an uneconomical service that can and is being provided by alternate providers.

34.

Given the number of BNAS customers that have migrated to alternate service providers since the application was filed, the Commission finds that the timeframe proposed by Bell Canada is appropriate.

35.

The Commission notes the assistance that Bell Canada has stated it will provide to municipal customers to migrate their services within the proposed timeframe.

36.

In light of the above, the Commission approves the application filed by Bell Canada. The destandardization of BNAS is effective as of the date of this order.

Secretary General

This document is available in alternative format upon request and may also be examined at the following Internet site: www.crtc.gc.ca