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Telecom Order CRTC 2003-365
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Ottawa, 8 September 2003
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Bell Canada
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Reference: Tariff Notice 6751
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Introduction of Single Number Reach
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The Commission approves the introduction of Single Number Reach service which will provide customers with a virtual telephone number that they can program to forward calls to where they are located, as well as send a message to a customer location while the customer is on the Internet, indicating that a message is waiting.
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The application
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1.
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The Commission received an application by Bell Canada, dated 16 May 2003, to revise its General Tariff in order to introduce item 2185, Single Number Reach (SNR) service. SNR would provide customers with a virtual telephone number that they can program to forward calls, as well as send a message to the customer while the customer is on the Internet, indicating that a message is waiting.
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2.
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Bell Canada proposed to offer SNR in two packages: Package A, basic SNR, at the rate of $14.95 per month, and Package B, a more feature-rich alternative than Package A, at a rate of $19.95 per month. Bell Canada indicated that for $5.00 per month, an SNR customer could add the Voice mail feature, and that for $5.95 per month, the Call Director feature could also be added. Bell Canada proposed to introduce a service charge of $35.00 for customers migrating from one package to another or adding the Voice mail or the Call Director features, but no service charge would apply for the initial provision of either package.
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3.
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Bell Canada filed a cost study and an imputation test in support of the proposed rates for SNR.
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4.
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Coincident with filing Tariff Notice 6751 (TN 6751), Bell Canada filed Tariff Notice 6752 (TN 6752), in which it proposed to de-standardize PrimeLine Executive service (PrimeLine) and then to withdraw it completely once PrimeLine customers were migrated to SNR.
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5.
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By letters distributed during the week of 19 May 2003, Bell Canada notified its PrimeLine customers of its proposal to de-standardize and withdraw PrimeLine (TN 6752) and to introduce SNR (TN 6751) to replace it.
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Process
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6.
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The Commission received comments from several PrimeLine subscribers supporting the introduction of SNR. The Commission also received comments, dated 28 May 2003 and 11 July 2003, from Unite Communications Corporation (Unite Communications), a service provider of messaging services. Bell Canada filed reply comments dated 8 July 2003.
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Unite Communications' comments
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7.
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Unite Communications stated that there was a great deal of overlap between Bell Canada's proposed SNR and some of the services offered by Unite Communications. It argued that the introduction of SNR was unfair and predatory, and requested that the Commission only approve SNR under the following conditions:
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(i) Bell Canada agreeing to disclose its numbers for scrutiny by an industry committee composed of industry members outside Bell Canada, such as Unite Communications. Unite Communications argued that it needed to be sure that Bell Canada was not using certain services not available to competitors, that it was using market prices for those facilities that are available to competitors, and that Bell Canada had planned for sufficient facilities and resources to offer the level of service proposed; and
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(ii) Bell Canada permitting current PrimeLine customers to port their old PrimeLine numbers by letting competitors take over these numbers.
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Bell Canada's reply
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8.
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Bell Canada stated that it had received many comments from customers supporting the launch of SNR. Bell Canada indicated that customer concerns focused on the withdrawal of PrimeLine rather than on the introduction of SNR. Bell Canada submitted that, as the tariff filings were independent of each other, it was in the best interest of customers that it be allowed to introduce SNR as soon as possible, regardless of the Commission's decision on the PrimeLine filing.
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9.
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Bell Canada noted that Unite Communications opposed the SNR filing, alleging it was unfair and predatory. Bell Canada submitted that it was difficult to determine the basis for this allegation since the imputation test it filed with its application demonstrated that the rates for SNR were compensatory.
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10.
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In regard to Unite Communications' concern that SNR would use services not available to competitors, Bell Canada stated that the network components used to provide SNR were digital trunks, digital network access, routers and servers. Bell Canada stated that all of these elements were available from either Bell Canada or from other suppliers on a competitive basis.
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11.
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Bell Canada stated that Unite Communications indicated that it was inappropriate for the company to have filed figures relating to SNR in confidence. Bell Canada noted that it had provided the Commission with economic evidence to support the proposed rates. Bell Canada submitted that the cost study filed in support of SNR met the regulatory requirements for the imputation test. Bell Canada reiterated that disclosure of the cost information filed with its application would allow its existing and potential competitors to develop more effective business strategies thereby causing Bell Canada specific direct harm. Bell Canada further submitted that Unite Communications had provided no compelling argument for disclosure of confidential information filed in relation to SNR.
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12.
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Bell Canada argued that SNR was a significant improvement over PrimeLine. It stated that SNR would provide the same range of features available through PrimeLine, as well as many new features that were not available with PrimeLine. Bell Canada also indicated that SNR would incorporate reliable technology that was flexible enough to accommodate future customer needs.
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Commission analysis and determinations
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13.
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The Commission notes that several subscribers to PrimeLine supported the introduction of SNR. Other subscribers' comments focused on the withdrawal of PrimeLine rather than on the introduction of SNR. The Commission is of the view that Bell Canada's application to introduce SNR can be considered independently of its application to de-standardize and subsequently withdraw PrimeLine. Consequently, comments that were filed on TN 6751 but pertain to the withdrawal of PrimeLine will be considered in the disposition of TN 6752.
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14.
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In regard to Unite Communications' concern that Bell Canada would be using services not available to competitors to provide SNR, the Commission is satisfied that the network components, the routers and the servers required to provide SNR are available from either Bell Canada or other suppliers.
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15.
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In regard to Unite Communications' concern with respect to whether market prices for services available to competitors were incorporated in the cost study, the Commission is satisfied that the costs of all the components used to provide SNR were included in the cost study. The Commission further notes that Bell Canada is not required to impute rates for the underlying network services that are available to competitors as none of the network components of SNR were designated as essential services.
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16.
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In regard to Unite Communications' concern that Bell Canada may not have sufficient facilities and resources to offer the level of service proposed for SNR, the Commission notes that Bell Canada has indicated that SNR would incorporate reliable technology that was flexible enough to accommodate future customer needs.
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17.
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Accordingly, the Commission considers that disclosure of Bell Canada's confidential information filed in relation to TN 6751 is unnecessary for scrutiny by an industry committee.
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18.
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The Commission notes that for a new service or a rate decrease, the proposed rates must be supported by and satisfy an imputation test. The Commission considers that the imputation test is the accepted method, under the current regulatory regime, of determining whether the proposed rates would be anti-competitive. The Commission finds that the proposed rates satisfy the imputation test, and are therefore compensatory and not unfair and predatory as alleged by Unite Communications.
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19.
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In Local competition, Telecom Decision CRTC 97-8, 1 May 1997, the Commission directed local exchange carriers to allow for porting of telephone numbers within an exchange. The Commission notes, in this regard, that Bell Canada stated that customers could keep their existing PrimeLine numbers when switching to SNR or to a competing service.
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20.
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In Regulatory framework for second price cap period, Telecom Decision CRTC 2002-34, 30 May 2002, the Commission concluded that when an incumbent local exchange carrier (ILEC) files a tariff application in respect of a new service offering, the ILEC must identify the service basket, sub-basket or service group to which it proposes to assign that service. The Commission notes that Bell Canada did not identify the service basket to which SNR should be classified. The Commission notes that PrimeLine is an uncapped service. As PrimeLine and SNR are similar, the Commission determines that SNR should also be classified as an uncapped service.
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21.
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In light of the above, the Commission approves Bell Canada's application.
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Secretary General
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This document is available in alternative format upon request and may also be examined at the following Internet site: http://www.crtc.gc.ca
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Date Modified: 2003-09-08