Telecom Decision CRTC 2002-72
Ottawa, 4 December 2002
Aliant Telecom Inc., Bell Canada, MTS Communications Inc. and Saskatchewan Telecommunications - Application to review and vary Order 2001-772
In this decision the Commission approves an application by Aliant Telecom Inc., Bell Canada, MTS Communications Inc. and Saskatchewan Telecommunications (SaskTel) to review and vary Zero-dialed access to emergency service providers, Order CRTC 2001-772, 19 October 2001 (Order 2001-772).
The Commission finds that Bell Canada, Maritime Tel & Tel Limited, NBTel Inc., NewTel Communications Inc., Island Telecom Inc., MTS Communications Inc. and SaskTel will not be required to file usage-based rates as had been required in Order 2001-772. The Commission approves, on a final basis, the rates that were originally proposed in the proceeding that led to Order 2001-772.
1. The Commission received an application dated 17 January 2002 by Aliant Telecom Inc., Bell Canada, MTS Communications Inc. and Saskatchewan Telecommunications (SaskTel) (collectively the applicants), pursuant to section 62 of the Telecommunications Act and Part VII of the CRTC Telecommunications Rules of Procedure, to review and vary Zero-dialed access to emergency service providers, Order CRTC 2001-772, 19 October 2001 (Order 2001-772).
2. The application was served on all parties to the proceeding that resulted in Order 2001-772. The Commission received no comments with respect to this application.
3. In Order 2001-772, the Commission granted final approval to the tariff provisions, excluding rates, for the Zero-dialed Emergency Call Routing Service (0-ECRS). The Commission, however, determined that the rates for the service should be maintained with interim approval pending the filing of further information.
4. In Order 2001-772, the Commission noted that the rates proposed by Bell Canada, Maritime Tel & Tel Limited, NBTel Inc., NewTel Communications Inc., Island Telecom Inc. and MTS Communications Inc. (collectively the companies) were based on a seven-year demand forecast for competitive local exchange carriers only. The Commission required the companies to resubmit their cost studies to take into account a larger base of potential customers comprised of wireless service providers, interexchange carriers, competitive pay telephone service providers and alternate operator services providers.
5. The Commission also found that the companies had not adequately justified a monthly charge as opposed to a usage-based compensation regime. The Commission expressed the view that a rate structure that featured a usage-based component would more appropriately reflect the costs of providing the service to users. The Commission therefore directed the companies to submit new rates with a usage-based component.
The applicants' position
6. The applicants requested that the Commission review and vary Order 2001-772 and approve, on a final basis, the 0-ECRS rates originally proposed by the companies in the proceeding that led to Order 2001-772.
7. In support of their request, the applicants submitted that there is substantial doubt as to the correctness of Order 2001-772 due to a fundamental change in circumstances since the introduction of 0-ECRS. The applicants further submitted that experience with the service since it was first approved in February 2000 indicates that implementation of a usage-based rate would result in significant additional costs for the companies and, in turn, for users of the service thereby defeating the purpose of ensuring low rates. According to the applicants, the rating mechanism contemplated in Order 2001-772 would also not be workable for certain types of 0-ECRS calls.
8. The applicants submitted that the 0-ECRS tariff proposals of Island Telecom Inc., now part of Aliant Telecom Inc., and SaskTel already reflected the larger base of customers.
9. With respect to the other companies, the applicants submitted that demand for 0-ECRS calling is limited and is not likely to grow as a result of the expansion of the base of customers. The applicants noted in this respect that 0-ECRS customers do not themselves originate calls but merely use the service to route calls originated by end-users.
10. The applicants stated that they have been providing the service for nearly two years and, based on this experience, now believe that the number of customers for this service will actually be more limited than reflected in the initial economic studies. They indicated that, since 0-ECRS was introduced at the beginning of 2000, the number of customers has been far less than the companies originally expected and submitted the original forecast would not materialize within the foreseeable future.
11. The applicants submitted that a usage-based rate is not feasible for areas where 9-1-1 service is not available. In this regard, they noted that, in areas where 9-1-1 service is not available, 0-ECRS customers call the Public Service Answering Position directly, using the list of the telephone numbers extracted from the companies' traffic operator position system of emergency response agencies located within the companies' operating territories (such list is referred to as TOPR). According to the applicants, there are no means for them to track, and subsequently bill, usage of TOPR listings. The applicants further argued that the associated costs of establishing a tracking system would vastly exceed the value of such tracking tools.
12. The applicants submitted that, in areas where 9-1-1 service is available, usage-based billing would involve the development and implementation of a customer information system, a call tracking system and a mechanized billing system. They argued that the introduction of usage-based billing would likely also result in additional billing processing and tracking costs for 0-ECRS customers.
13. The applicants argued that there is substantial doubt as to the correctness of Order 2001-772 in that the Commission's determination is premised on the incorrect assumption that the larger base of eligible customers would result in a lower rate.
14. The applicants submitted that a rate without a usage component would be more appropriate for 0-ECRS calls originated in those areas where usage cannot be tracked. They further argued that even in those areas where usage could theoretically be tracked, such a rate would also be more appropriate because of the significant costs associated with tracking usage and billing.
15. The Commission finds that demand for 0-ECRS will not likely increase by expanding the base of customers.
16. The Commission also finds that in areas where 9-1-1 is not available, it is not possible to track usage and as a result a usage-based rate is not feasible. In addition, the Commission is of the view that, in areas where 9-1-1 service is available, the costs of implementing a tracking and billing system would defeat the Commission's original objective of minimizing costs to users of the service.
17. The Commission therefore determines that a usage-based rate for 0-ECRS would not be appropriate in the present circumstances.
18. In light of the above, the Commission concludes that the applicants have demonstrated that there is substantial doubt as to the correctness of Order 2001-772 and approves, on a final basis, the 0-ECRS rates originally proposed by the companies.
19. The companies are directed to issue revised tariff pages forthwith consistent with this decision.
This document is available in alternative format upon request and may also be examined at the following Internet site: www.crtc.gc.ca
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